Legal Opinion

John D. Shea v. Commissioner

United States Tax Court

Decided April 1, 1999No. 10841-95, 23549-96Unknown

1Opinion of the Court

112 T.C. No. 14

UNITED STATES TAX COURT JOHN D. SHEA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 10841-95, 23549-96. Filed April 1, 1999. P and his wife filed joint returns for 1990 and 1991. P submitted a delinquent return for 1992 that was filed as a joint return. R determined that P underreported business receipts for 1990, 1991, and 1992 based on deposits to P's bank accounts and also disallowed business deductions claimed on P's returns. In the notice of deficiency for 1992, R determined that P's proper filing status for 1992 was married filing separately. Even…

2Cases cited27 opinions

  1. New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
  2. Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
  3. Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
  4. Indopco, Inc. v. CommissionerSupreme Court of the United States · 1992
  5. Commissioner v. HeiningerSupreme Court of the United States · 1943

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