Legal Opinion

Carsendino v. Commissioner

United States Tax Court

Decided February 24, 1994No. Docket No. 15005-91Unpublished

P and her husband, H, filed joint returns over a 4-year period. R determined deficiencies and additions to tax against P and H based upon the omission of items from gross income during each year in that period. H was convicted of attempting to evade taxes based upon those omissions.

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P and her husband, H, filed joint returns over a 4-year period. R determined deficiencies and additions to tax against P and H based upon the omission of items from gross income during each year in that period. H was convicted of attempting to evade taxes based upon those omissions. The normal 3-year statute of limitations having run, R contends that assessment and collection of the deficiencies are not time barred since H, who was responsible for preparing the returns, filed fraudulent returns with intent to avoid tax. P contends that even if assessment and collection are not time barred,…

1Opinion of the Court

ROSIN CARSENDINO, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Carsendino v. Commissioner

Docket No. 15005-91

United States Tax Court

T.C. Memo 1994-79; 1994 Tax Ct. Memo LEXIS 80; 67 T.C.M. (CCH) 2248;

February 24, 1994, Filed

Decision will be entered for respondent.

P and her husband, H, filed joint returns over a 4-year period. R determined deficiencies and additions to tax against P and H based upon the omission of items from gross income during each year in that period. H was convicted of attempting to evade taxes based upon those omissions. The normal 3-year statute of…

2Cases cited16 opinions

  1. Tokarski v. CommissionerUnited States Tax Court · 1986
  2. Grosshandler v. CommissionerUnited States Tax Court · 1980
  3. Pallottini v. CommissionerUnited States Tax Court · 1988
  4. Parks v. CommissionerUnited States Tax Court · 1990
  5. Terzian v. CommissionerUnited States Tax Court · 1979

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