Legal Opinion

Hesselink v. Commissioner

United States Tax Court

Decided July 30, 1991No. Docket No. 31528-88Published

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.

Read the full summary

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

  1. Payne v. TennesseeSupreme Court of the United States · 1991
  2. Shearson/American Express Inc. v. McMahonSupreme Court of the United States · 1987
  3. Vasquez v. HillerySupreme Court of the United States · 1986
  4. McNally v. United StatesSupreme Court of the United States · 1987
  5. Helvering v. MitchellSupreme Court of the United States · 1938

22 more not listed; retrieve them via the Exa API.

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API