Medeiros v. Commissioner
United States Tax Court
Held, the 100-percent penalty tax imposed by sec. 6672(a), I.R.C. 1954, assessed against petitioner and paid by him, is not deductible under either sec. 162(a) or sec. 165(c)(1). Sec. 162(f). Held, further, the Tax Court does not have jurisdiction to determine petitioner's liability for the penalty tax imposed by sec. 6672(a).
1Opinion of the Court
Drennen, Judge:
Respondent determined deficiencies in petitioners’ income taxes and additions to tax for the following years and in the following amounts:
Addition to tax
Year Deficiency Sec. 6651(a) Sec. 6653(a)
1972 $21,498.36 $5,374.59 $1,580.92
1973 13,599.90 3,399.98 1,398.55
1974 13,698.33 3,424.58 1,320.51
Petitioners having conceded all other adjustments made in the notice of deficiency, including the additions to tax, the only issue for decision is whether petitioner is entitled to a deduction for the year 1972 in the amount of $11,290.65 for the 100-percent penalty tax imposed by section…
2Cases cited11 opinions
- Southern Pacific Transp. Co. v. CommissionerUnited States Tax Court · 1980
- Shaw v. United StatesCourt of Appeals for the Ninth Circuit · 1964
- Stamos v. CommissionerUnited States Tax Court · 1954
- United States v. Frank H. Molitor, Frank H. Molitor v. United StatesCourt of Appeals for the Ninth Circuit · 1964
- Wilt v. CommissionerUnited States Tax Court · 1973
6 more not listed; retrieve them via the Exa API.
3Cited by67 opinions
- Naftel v. CommissionerUnited States Tax Court · 1985
- Pyo v. CommissionerUnited States Tax Court · 1984
- Kluger v. CommissionerUnited States Tax Court · 1984
- Estate of Young v. CommissionerUnited States Tax Court · 1983
- Judge v. CommissionerUnited States Tax Court · 1987
62 more not listed; retrieve them via the Exa API.