Legal Opinion

Anderson v. Commissioner

United States Tax Court

Decided July 6, 1993No. Docket No. 27807-90UnpublishedCited by 1 opinion

H and W overpaid their Federal income taxes for 1986 and 1987 through withholding. H and W's period for filing their 1986 income tax return was extended until Oct. 15, 1987. R mailed notices of deficiency to W for 1986 and 1987 on Sept. 19, 1990. R mailed notices of deficiency to H for 1986 and 1987 on Nov. 14, 1990. H and W filed joint income tax returns for 1986 and 1987 on or about Apr. 10, 1992. Held, Under sec. 6512(b)(3)(B), I.R.C. 1986, the statute of limitations on…

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H and W overpaid their Federal income taxes for 1986 and 1987 through withholding. H and W's period for filing their 1986 income tax return was extended until Oct. 15, 1987. R mailed notices of deficiency to W for 1986 and 1987 on Sept. 19, 1990. R mailed notices of deficiency to H for 1986 and 1987 on Nov. 14, 1990. H and W filed joint income tax returns for 1986 and 1987 on or about Apr. 10, 1992. Held, Under sec. 6512(b)(3)(B), I.R.C. 1986, the statute of limitations on credit or refund of a tax overpayment determined by the Tax Court requires application of rules to facts existing at the…

1Opinion of the Court

VERNON FRANKLIN ANDERSON, SR., AND ANN WATSON ANDERSON, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Anderson v. Commissioner

Docket No. 27807-90

United States Tax Court

T.C. Memo 1993-288; 1993 Tax Ct. Memo LEXIS 293; 66 T.C.M. (CCH) 4;

July 6, 1993, Filed

H and W overpaid their Federal income taxes for 1986 and 1987 through withholding. H and W's period for filing their 1986 income tax return was extended until Oct. 15, 1987. R mailed notices of deficiency to W for 1986 and 1987 on Sept. 19, 1990. R mailed notices of deficiency to H for 1986 and 1987 on Nov. 14, 1990. H and W filed…

2Cases cited15 opinions

  1. Pallottini v. CommissionerUnited States Tax Court · 1988
  2. Rothensies v. Electric Storage Battery Co.Supreme Court of the United States · 1946
  3. Minahan v. CommissionerUnited States Tax Court · 1987
  4. Pierre Boulez v. Commissioner of Internal RevenueCourt of Appeals for the D.C. Circuit · 1987
  5. Boulez v. CommissionerUnited States Tax Court · 1981

10 more not listed; retrieve them via the Exa API.

3Cited by1 opinion

  1. Butts v. Comm'rUnited States Tax Court · 2015

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