Legal Opinion

Wilson v. Comm'r

United States Tax Court

Decided June 12, 2002No. 13703-01Published

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

  1. Naftel v. CommissionerUnited States Tax Court · 1985
  2. Monge v. CommissionerUnited States Tax Court · 1989
  3. Normac, Inc. v. CommissionerUnited States Tax Court · 1988
  4. Estate of Di Rezza v. CommissionerUnited States Tax Court · 1982
  5. Meyer v. CommissionerUnited States Tax Court · 1991

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