Legal Opinion

Risman v. Commissioner

United States Tax Court

Decided March 16, 1993No. Docket No. 11429-91Published

Held: On the facts of this case, petitioners' remittance accompanying a Form 4868 for 1981 is deemed to be a deposit, not a payment of tax.

1Opinion of the Court

ROBERT B. RISMAN AND ELEANOR RISMAN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Risman v. Commissioner

Docket No. 11429-91

United States Tax Court

100 T.C. 191; 1993 U.S. Tax Ct. LEXIS 13; 100 T.C. No. 13;

March 16, 1993, Filed

Held: On the facts of this case, petitioners' remittance accompanying a Form 4868 for 1981 is deemed to be a deposit, not a payment of tax.

Robert B. Risman and Eleanor Risman, pro sese.

For respondent: Marvis A. Knospe.

SWIFT

SWIFT

SWIFT, Judge: Respondent determined deficiencies in petitioners' joint Federal income taxes and additions to tax as follows:

Additions…

2Cases cited15 opinions

  1. Rosenman v. United StatesSupreme Court of the United States · 1945
  2. Crocker v. CommissionerUnited States Tax Court · 1989
  3. Arthur C. Ewing A/K/A A. Clifford Ewing Maxine H. Ewing v. United StatesCourt of Appeals for the Fourth Circuit · 1990
  4. Busser v. United StatesCourt of Appeals for the Third Circuit · 1942
  5. Francis H. Ameel, Administrator D.B.N. Estate of Mary E. Ameel v. United StatesCourt of Appeals for the Sixth Circuit · 1970

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