Vigon v. Comm'r
United States Tax Court
P submitted to R nine Forms 1041, "U.S. Income Tax Return for Estates and Trusts"; and R assessed against P nine $5,000 penalties under I.R.C. sec. 6702 (for "frivolous tax submissions"), which are not subject to deficiency procedures and for which R asserts there is no statute of limitations.
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P submitted to R nine Forms 1041, "U.S. Income Tax Return for Estates and Trusts"; and R assessed against P nine $5,000 penalties under I.R.C. sec. 6702 (for "frivolous tax submissions"), which are not subject to deficiency procedures and for which R asserts there is no statute of limitations. R issued to P a notice of Federal tax lien under I.R.C. sec. 6320(a), and P requested a CDP hearing, during which under I.R.C. sec. 6330(c)(2)(B) he challenged his underlying liability for the penalties. The IRS's Office of Appeals issued a determination sustaining the penalty liabilities and the notice…
1Opinion of the Court
DEAN MATTHEW VIGON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Vigon v. Comm'r
Docket No. 28788-14L.
United States Tax Court
2017 U.S. Tax Ct. LEXIS 37; 149 T.C. No. 4;
July 24, 2017, Filed
An appropriate order will be issued.
P submitted to R nine Forms 1041, "U.S. Income Tax Return for Estates and Trusts"; and R assessed against P nine $5,000 penalties under I.R.C. sec. 6702 (for "frivolous tax submissions"), which are not subject to deficiency procedures and for which R asserts there is no statute of limitations. R issued to P a notice of Federal tax lien under I.R.C. sec.…
2Cases cited15 opinions
- United States v. TestanSupreme Court of the United States · 1976
- United States v. Concentrated Phosphate Export Assn., Inc.Supreme Court of the United States · 1968
- Naftel v. CommissionerUnited States Tax Court · 1985
- Emma R. Dorl v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1974
- Dorl v. CommissionerUnited States Tax Court · 1972
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