Howell v. Commissioner
United States Tax Court
On May 14, 1980, respondent mailed a notice of deficiency to petitioner in which he determined first tier and second tier excise taxes under secs. 4941(a)(1) and 4941(b)(1), I.R.C. 1954, as amended, for acts of self-dealing in 1973, 1974, and 1975. On Oct. 14, 1980, a petition was filed disputing those determinations. On Dec. 24, 1980, Pub.
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On May 14, 1980, respondent mailed a notice of deficiency to petitioner in which he determined first tier and second tier excise taxes under secs. 4941(a)(1) and 4941(b)(1), I.R.C. 1954, as amended, for acts of self-dealing in 1973, 1974, and 1975. On Oct. 14, 1980, a petition was filed disputing those determinations. On Dec. 24, 1980, Pub. L. 96-596, 94 Stat. 3469, was enacted which corrected jurisdictional defects of sec. 4941(b)(1) found by this Court in Adams v. Commissioner, 72 T.C. 81 (1979), on appeal (2d Cir., June 23, 1981). Held, the amendments made to the Internal Revenue Code by…
1Opinion of the Court
Rosemary Howell, Petitioner 1 v. Commissioner of Internal Revenue, Respondent
Howell v. Commissioner
Docket No. 19104-80
United States Tax Court
77 T.C. 916; 1981 U.S. Tax Ct. LEXIS 41;
October 22, 1981, Filed
On May 14, 1980, respondent mailed a notice of deficiency to petitioner in which he determined first tier and second tier excise taxes under secs. 4941(a)(1) and 4941(b)(1), I.R.C. 1954, as amended, for acts of self-dealing in 1973, 1974, and 1975. On Oct. 14, 1980, a petition was filed disputing those determinations. On Dec. 24, 1980, Pub. L. 96-596, 94 Stat. 3469, was enacted which…
Also in this document: Concurrence · Tannenwald; Concurrence · Scott; Concurrence · Fay.
2Cases cited38 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Helvering v. MitchellSupreme Court of the United States · 1938
- Brushaber v. Union Pacific RailroadSupreme Court of the United States · 1916
- Crooks v. HarrelsonSupreme Court of the United States · 1930
- Nichols v. CoolidgeSupreme Court of the United States · 1927
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