Legal Opinion

Koufman v. Commissioner

United States Tax Court

Decided December 13, 1977No. Docket No. 8770-73Published

After entry of decision, the Commissioner moved to amend his answer to claim an increased deficiency on the ground that the claim therefor was made "at or before the hearing or a rehearing" within the meaning of sec. 6214(a), I.R.C. 1954. Held, such claim was not made "at or before the hearing."

1Opinion of the Court

Manuel M. Koufman and Charlotte Koufman, Petitioners v. Commissioner of Internal Revenue, Respondent

Koufman v. Commissioner

Docket No. 8770-73

United States Tax Court

69 T.C. 473; 1977 U.S. Tax Ct. LEXIS 7;

December 13, 1977, Filed

After entry of decision, the Commissioner moved to amend his answer to claim an increased deficiency on the ground that the claim therefor was made "at or before the hearing or a rehearing" within the meaning of sec. 6214(a), I.R.C. 1954. Held, such claim was not made "at or before the hearing."

David R. Andelman, for the petitioners.

Amy Robertson Goldson, for the…

2Cases cited18 opinions

  1. Robert A. Henningsen, and Cross and R.A. And Margaret Henningsen v. Commissioner of Internal Revenue, AndCourt of Appeals for the Fourth Circuit · 1957
  2. Haft Trust v. CommissionerUnited States Tax Court · 1974
  3. Robin Haft Trust v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1975
  4. Koufman v. CommissionerUnited States Tax Court · 1977
  5. Helvering v. Edison Securities CorporationCourt of Appeals for the Fourth Circuit · 1935

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