Cluck v. Commissioner
United States Tax Court
P is married to E. E is not a petitioner in this case. E's mother, M, died in 1983, leaving E and his brothers a tract of land (G). G was sold in 1984. P and E have filed joint Federal income tax returns since 1986. P and E claimed net operating loss (NOL) deductions on their 1987 and 1988 returns, consisting of unused NOL's carried forward from E's 1983, 1984, and 1985 returns and from P and E's 1986 joint return.
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P is married to E. E is not a petitioner in this case. E's mother, M, died in 1983, leaving E and his brothers a tract of land (G). G was sold in 1984. P and E have filed joint Federal income tax returns since 1986. P and E claimed net operating loss (NOL) deductions on their 1987 and 1988 returns, consisting of unused NOL's carried forward from E's 1983, 1984, and 1985 returns and from P and E's 1986 joint return. In 1989, after a dispute with R regarding the value of G for purposes of M's estate's Federal estate tax liability, E and his brothers, who each had owned a one-fourth interest in…
1Opinion of the Court
Parr, Judge:
Respondent determined deficiencies in and additions to petitioner’s Federal income tax for taxable years 1987 and 1988 as follows:
Additions to tax
Deficiency Sec. 6651 Sec. 6653(a)(1)(A) Sec. 6653(a)(1)(B) Sec. 6661 £
1987 $7,013 $1,380 $620 1 $1,753
35,574 13,398 2,856 8,894 00 00 <Ji
Although petitioner filed joint returns with her husband, Elwood Cluck (Elwood), Elwood is not a party herein because his liability was determined and discharged in the U.S. Bankruptcy Court for the Western District of Texas. Cluck v. United States, 165 Bankr. 1005 (W.D. Tex. 1993). After concessions,1…
2Cases cited37 opinions
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Neely v. CommissionerUnited States Tax Court · 1985
- Bixby v. CommissionerUnited States Tax Court · 1972
- Wichita Term. El. Co. v. Commissioner of Int. R.Court of Appeals for the Tenth Circuit · 1947
- Tokarski v. CommissionerUnited States Tax Court · 1986
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3Cited by57 opinions
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- Hill v. Comm'rUnited States Tax Court · 2003
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