Legal Opinion

Vigon v. Comm'r

United States Tax Court

Decided July 24, 2017No. Docket No. 28788-14LPublished

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

  1. United States v. TestanSupreme Court of the United States · 1976
  2. United States v. Concentrated Phosphate Export Assn., Inc.Supreme Court of the United States · 1968
  3. Naftel v. CommissionerUnited States Tax Court · 1985
  4. Emma R. Dorl v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1974
  5. Dorl v. CommissionerUnited States Tax Court · 1972

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