Bassett v. Commissioner
United States Tax Court
P earned a substantial amount of income as a child actress in 1985, 1986, and 1987 when she was 11, 12, 13, and 14 years old. P's parents were her guardians under applicable State law and were actively involved in assisting her acting career. P did not file her own returns for those years and did not have the capacity to file because of her youth. P's parents did not file returns for P. P's parents did not have reasonable cause for not filing P's returns.
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P earned a substantial amount of income as a child actress in 1985, 1986, and 1987 when she was 11, 12, 13, and 14 years old. P's parents were her guardians under applicable State law and were actively involved in assisting her acting career. P did not file her own returns for those years and did not have the capacity to file because of her youth. P's parents did not file returns for P. P's parents did not have reasonable cause for not filing P's returns. Held, sec. 6012(b)(2), I.R.C., required P's parents to file P's returns for her. Held, further, P is liable for the additions to tax for…
1Opinion of the Court
COLVIN, Judge:
Respondent determined deficiencies of $5,218 for 1985, $15,503 for 1986, and $3,043 for 1987 for petitioner, and additions to tax as follows:
Additions to tax
Sec. Sec. Sec. Year 6653(a)(1) 6653(a)(2) 6651(a) Sec. 6654
1985 $261 1 $1,149 $253
Additions to tax
Sec. Sec. Sec. Year 6653(a)(1)(A) 6653(a)(1)(B) 6651(a) Sec. 6654
$3,767 $723 1O t> ■m-CD 00 a>
761 Cn to r-i CD 00 <3
The parties have settled all issues except for those pertaining to additions to tax. The following issues remain to be decided:
1. Whether petitioner’s parents were required by section 6012(b)(2) to file returns for…
2Cases cited13 opinions
- United States v. BoyleSupreme Court of the United States · 1985
- Neely v. CommissionerUnited States Tax Court · 1985
- Bixby v. CommissionerUnited States Tax Court · 1972
- Dunbar v. DunbarSupreme Court of the United States · 1903
- Emmons v. CommissionerUnited States Tax Court · 1989
8 more not listed; retrieve them via the Exa API.
3Cited by9 opinions
- Martin Ice Cream Co. v. Comm'rUnited States Tax Court · 1998
- Skye Bassett v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1995
- Benson v. Comm'rUnited States Tax Court · 2004
- Bassett v. CommissionerUnited States Tax Court · 1993
- Hodges v. Comm'rUnited States Tax Court · 2005
4 more not listed; retrieve them via the Exa API.