Carsendino v. Commissioner
United States Tax Court
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.
Read the full summary
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
- Tokarski v. CommissionerUnited States Tax Court · 1986
- Grosshandler v. CommissionerUnited States Tax Court · 1980
- Pallottini v. CommissionerUnited States Tax Court · 1988
- Parks v. CommissionerUnited States Tax Court · 1990
- Terzian v. CommissionerUnited States Tax Court · 1979
11 more not listed; retrieve them via the Exa API.