Estate of Sperling v. Commissioner
United States Tax Court
1. Husband signed wife's name to waivers extending time within which to assess deficiencies on joint returns for 1951 and 1952. Held, assessment of deficiencies against wife for those years barred by statute of limitations. 2. Held, petitioner not entitled to deductions for purchases in excess of amounts allowed by respondent for the years 1953 and 1954. 3. Held, petitioner is entitled to dependency credit for son for year 1953. 4. Held, petitioner not entitled to deduction…
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1. Husband signed wife's name to waivers extending time within which to assess deficiencies on joint returns for 1951 and 1952. Held, assessment of deficiencies against wife for those years barred by statute of limitations. 2. Held, petitioner not entitled to deductions for purchases in excess of amounts allowed by respondent for the years 1953 and 1954. 3. Held, petitioner is entitled to dependency credit for son for year 1953. 4. Held, petitioner not entitled to deduction for alleged Christmas gifts for 1954. 5. Held, petitioner is liable for additions to tax for negligence for the years…
1Opinion of the Court
Estate of Lillian Virginia Sperling, Deceased, Warren Richard Sperling, Administrator v. Commissioner.
Estate of Sperling v. Commissioner
Docket No. 88167.
United States Tax Court
T.C. Memo 1963-260; 1963 Tax Ct. Memo LEXIS 81; 22 T.C.M. (CCH) 1301; T.C.M. (RIA) 63260;
September 26, 1963
1. Husband signed wife's name to waivers extending time within which to assess deficiencies on joint returns for 1951 and 1952. Held, assessment of deficiencies against wife for those years barred by statute of limitations.
2. Held, petitioner not entitled to deductions for purchases in excess of amounts allowed by…
2Cases cited6 opinions
- Courtney v. CommissionerUnited States Tax Court · 1957
- Howell v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1949
- Howell v. CommissionerUnited States Tax Court · 1948
- Switzer v. CommissionerUnited States Tax Court · 1953
- William G. Lias v. Commissioner of Internal Revenue, William G. Lias and Alice B. Lias, His Wife v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1956
1 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
- Mark Buchine v. Commissioner of Internal Revenue Service, Karen C. Buchine v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Fifth Circuit · 1994
- Buchine v. C.I.R.Court of Appeals for the Fifth Circuit · 1994
- Buchine v. C.I.R.Court of Appeals for the Fifth Circuit · 1994