Kotmair v. Commissioner
United States Tax Court
P, an individual and a tax protester, failed to file income tax returns for 1975 and 1976. P was thereafter convicted of willful failure to file returns for these years, under sec. 7203, I.R.C. 1954. Under the facts: Held, P's income for the years 1975 and 1976 redetermined. Held, P is not entitled to recompute his income under the completed contract method.
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P, an individual and a tax protester, failed to file income tax returns for 1975 and 1976. P was thereafter convicted of willful failure to file returns for these years, under sec. 7203, I.R.C. 1954. Under the facts: Held, P's income for the years 1975 and 1976 redetermined. Held, P is not entitled to recompute his income under the completed contract method. Held, P is not liable for additions to tax under sec. 6653(b), I.R.C. 1954. Held, the principles of collateral estoppel apply to proposed additions to tax under secs. 6651(a)(1) and 6653(a), I.R.C. 1954.
1Opinion of the Court
John B. Kotmair, Jr., Petitioner v. Commissioner of Internal Revenue, Respondent
Kotmair v. Commissioner
Docket No. 6716-84
United States Tax Court
86 T.C. 1253; 1986 U.S. Tax Ct. LEXIS 93; 86 T.C. No. 73;
June 19, 1986, Filed
Decision will be entered under Rule 155.
P, an individual and a tax protester, failed to file income tax returns for 1975 and 1976. P was thereafter convicted of willful failure to file returns for these years, under sec. 7203, I.R.C. 1954. Under the facts: Held, P's income for the years 1975 and 1976 redetermined. Held, P is not entitled to recompute his income under the…
Also in this document: Concurrence; Dissent.
2Cases cited43 opinions
- Montana v. United StatesSupreme Court of the United States · 1979
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Spies v. United StatesSupreme Court of the United States · 1943
- Rowlee v. CommissionerUnited States Tax Court · 1983
- United States v. MurdockSupreme Court of the United States · 1934
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