Wilson v. Commissioner
United States Tax Court
Held, for purposes of determining when a Federal income tax return is filed, judicial notice is taken of Internal Revenue Manual provisions explaining the meaning of the document locator numbers stamped by the Internal Revenue Service on Federal income tax returns.
1Opinion of the Court
SUPPLEMENTAL FINDINGS OF FACT AND OPINION
Goffe, Judge'.
On April 21, 1981, we filed our Findings of Fact and Opinion (76 T.C. 623 (1981)) in which we upheld with a minor modification the Commissioner’s reconstruction of petitioners’ gross incomes for the years 1969 through 1972; held, that respondent failed to prove that petitioner Dewey Wilson filed a fraudulent return for 1971; and held, that petitioners filed a fraudulent return for 1972. We based our holding as to Dewey’s fraud for 1971 in part upon respondent’s failure to prove when Dewey’s 1971 return was filed, because there were…
2Cases cited1 opinion
- Wilson v. CommissionerUnited States Tax Court · 1981
3Cited by23 opinions
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- Coleman v. CommissionerUnited States Tax Court · 1988
- Lerch v. CommissionerUnited States Tax Court · 1987
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