Conklin v. Commissioner
United States Tax Court
P and T, husband and wife, filed joint returns for the years at issue. R issued to T a notice of deficiency covering items 1, 2, 3, 4, and 5. T paid the deficiencies.
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P and T, husband and wife, filed joint returns for the years at issue. R issued to T a notice of deficiency covering items 1, 2, 3, 4, and 5. T paid the deficiencies. Subsequently, R issued a notice of deficiency to P covering items 1 through 5 identical to those in the notice to T, and items 6, 7, 8, and 9. Before trial, R conceded, with respect to P, items 2, 3, 6, 7, 8, and 9, and the parties settled item 4. Held, the Court is not deprived of jurisdiction by the payments by T, nor by the parties' resolution of some of the items. Item 1 involved charitable contribution deductions P claimed…
1Opinion of the Court
William T. Conklin, Petitioner v. Commissioner of Internal Revenue, Respondent
Conklin v. Commissioner
Docket No. 40976-85
United States Tax Court
91 T.C. 41; 1988 U.S. Tax Ct. LEXIS 87; 91 T.C. No. 5;
July 18, 1988; As amended July 27, 1988 July 18, 1988, Filed
P and T, husband and wife, filed joint returns for the years at issue. R issued to T a notice of deficiency covering items 1, 2, 3, 4, and 5. T paid the deficiencies. Subsequently, R issued a notice of deficiency to P covering items 1 through 5 identical to those in the notice to T, and items 6, 7, 8, and 9. Before trial, R conceded, with…
2Cases cited29 opinions
- Wong Sun v. United StatesSupreme Court of the United States · 1963
- Welch v. HelveringSupreme Court of the United States · 1933
- Nix v. WilliamsSupreme Court of the United States · 1984
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
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