Legal Opinion

Hatfield v. Commissioner

United States Tax Court

Decided September 12, 1977No. Docket No. 2399-76Published

P filed a Form 1040 for 1974 which did not disclose her gross income or give any information with regard to her tax liability for such year. Held: (1) Federal Reserve notes are not accounts receivable and are to be reported as income in accordance with a taxpayer's method of accounting; and (2) the document filed by P was not a "return," and the Commissioner properly imposed the additions to the tax provided in secs. 6651(a) and 6653(a), I.R.C. 1954.

1Opinion of the Court

Lou M. Hatfield, Petitioner v. Commissioner of Internal Revenue, Respondent

Hatfield v. Commissioner

Docket No. 2399-76

United States Tax Court

68 T.C. 895; 1977 U.S. Tax Ct. LEXIS 50;

September 12, 1977, Filed

Decision will be entered for the respondent.

P filed a Form 1040 for 1974 which did not disclose her gross income or give any information with regard to her tax liability for such year. Held: (1) Federal Reserve notes are not accounts receivable and are to be reported as income in accordance with a taxpayer's method of accounting; and (2) the document filed by P was not a "return," and the…

2Cases cited26 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Marchetti v. United StatesSupreme Court of the United States · 1968
  3. Bixby v. CommissionerUnited States Tax Court · 1972
  4. Gajewski v. CommissionerUnited States Tax Court · 1976
  5. United States v. SullivanSupreme Court of the United States · 1927

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