Hesselink v. Commissioner
United States Tax Court
After being investigated by respondent and after being indicated and pleading guilty to criminal charges for failing to file Federal income tax returns for 1980 through 1983, petitioner, in compliance with the sentence imposed by the Federal district court, filed delinquent tax returns.
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After being investigated by respondent and after being indicated and pleading guilty to criminal charges for failing to file Federal income tax returns for 1980 through 1983, petitioner, in compliance with the sentence imposed by the Federal district court, filed delinquent tax returns. Held, Under sec. 1.6661-2(d)(2), Income Tax Regs., in computing petitioner's liability for additions to tax under sec. 6661, I.R.C. 1954, amounts of tax shown on petitioner's delinquent tax returns are to be ignored.
1Opinion of the Court
THOMAS LEE HESSELINK, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Hesselink v. Commissioner
Docket No. 31528-88
United States Tax Court
97 T.C. 94; 1991 U.S. Tax Ct. LEXIS 66; 97 T.C. No. 7;
July 30, 1991, Filed
Decision will be entered for the respondent.
After being investigated by respondent and after being indicated and pleading guilty to criminal charges for failing to file Federal income tax returns for 1980 through 1983, petitioner, in compliance with the sentence imposed by the Federal district court, filed delinquent tax returns. Held, Under sec. 1.6661-2(d)(2), Income Tax…
Also in this document: Dissent.
2Cases cited27 opinions
- Payne v. TennesseeSupreme Court of the United States · 1991
- Shearson/American Express Inc. v. McMahonSupreme Court of the United States · 1987
- Vasquez v. HillerySupreme Court of the United States · 1986
- McNally v. United StatesSupreme Court of the United States · 1987
- Helvering v. MitchellSupreme Court of the United States · 1938
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