Sadler v. Commissioner
United States Tax Court
P, a tax attorney, was the president and sole shareholder of six corporations. P prepared his own Forms W-2 for 1989 and 1990 from these corporations. The Forms W-2 listed large amounts of Federal income tax withheld.
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P, a tax attorney, was the president and sole shareholder of six corporations. P prepared his own Forms W-2 for 1989 and 1990 from these corporations. The Forms W-2 listed large amounts of Federal income tax withheld. The corporations did not deposit with the IRS or withhold any Federal income taxes on the wages earned by P. On his tax returns for 1989 and 1990, P reported the correct tax imposed under subtitle A; however, P also reported as withholdings the amounts listed on the false Forms W-2. Held: P had an "underpayment" of tax for 1989 and 1990. See sec. 6664(a), I.R.C.; sec. 1.6664-2,…
1Opinion of the Court
Vasquez, Judge:
Respondent determined the following deficiency in and penalties on petitioner’s Federal income tax:
Penalties Year Deficiency sec. 6663
$19,797.59 $44,473.19 I — 1 CO 00 CD
19,500.00 M CO CD O
By amendment to answer, respondent increased the amount of the fraud penalty for 1989 to $55,947.37.
Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. After concessions,1 the issues for decision are (1) whether petitioner is liable for the fraud…
2Cases cited16 opinions
- Spies v. United StatesSupreme Court of the United States · 1943
- Stone v. CommissionerUnited States Tax Court · 1971
- Gajewski v. CommissionerUnited States Tax Court · 1976
- Beaver v. CommissionerUnited States Tax Court · 1970
- Otsuki v. CommissionerUnited States Tax Court · 1969
11 more not listed; retrieve them via the Exa API.
3Cited by33 opinions
- Feller v. CommissionerUnited States Tax Court · 2010
- Cooley v. Comm'rUnited States Tax Court · 2004
- John E. Rogers & Frances L. Rogers v. CommissionerUnited States Tax Court · 2018
- Edward Anthony Purvis & Maureen Helena Purvis v. CommissionerUnited States Tax Court · 2020
- Maciel v. Comm'rUnited States Tax Court · 2004
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