Wilson v. Comm'r
United States Tax Court
In conjunction with a criminal prosecution for tax evasion, P executed a Plea Agreement in which he agreed to file delinquent Federal income tax returns and report specific amounts of income. After assessing the tax liabilities reported on the delinquent returns, R sent P a notice of deficiency determining only additions to tax for fraudulent failure to file and failure to pay estimated tax under secs. 6651(f) and 6654(a), I.R.C., respectively.
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In conjunction with a criminal prosecution for tax evasion, P executed a Plea Agreement in which he agreed to file delinquent Federal income tax returns and report specific amounts of income. After assessing the tax liabilities reported on the delinquent returns, R sent P a notice of deficiency determining only additions to tax for fraudulent failure to file and failure to pay estimated tax under secs. 6651(f) and 6654(a), I.R.C., respectively. P filed a petition for redetermination. R moved to dismiss for lack of jurisdiction, arguing that the deficiency notice was invalid because R had not…
1Opinion of the Court
RICHARD A. WILSON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Wilson v. Comm'r
No. 13703-01
United States Tax Court
118 T.C. 537; 2002 U.S. Tax Ct. LEXIS 34; 118 T.C. No. 33;
June 12, 2002, Filed
Respondent's Motion to Dismiss for Lack of Jurisdiction granted.
In conjunction with a criminal prosecution for tax evasion,
P executed a Plea Agreement in which he agreed to file
delinquent Federal income tax returns and report specific
amounts of income. After assessing the tax liabilities reported
on the delinquent returns, R sent P a notice of deficiency
determining only additions to tax for…
2Cases cited8 opinions
- Naftel v. CommissionerUnited States Tax Court · 1985
- Monge v. CommissionerUnited States Tax Court · 1989
- Normac, Inc. v. CommissionerUnited States Tax Court · 1988
- Estate of Di Rezza v. CommissionerUnited States Tax Court · 1982
- Meyer v. CommissionerUnited States Tax Court · 1991
3 more not listed; retrieve them via the Exa API.