Mendes v. Comm'r
United States Tax Court
P has been continuously incarcerated since June 17, 1988. For P's 1988 taxable year, R (1) determined a tax deficiency based upon amounts reported on information returns as having been paid to P during that year, (2) imposed the 10-percent additional tax under sec. 72(t)(1), I.R.C., and (3) determined that P was subject to additions to tax under secs. 6651(a)(1), 6653(a)(1), and 6654, I.R.C.
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P has been continuously incarcerated since June 17, 1988. For P's 1988 taxable year, R (1) determined a tax deficiency based upon amounts reported on information returns as having been paid to P during that year, (2) imposed the 10-percent additional tax under sec. 72(t)(1), I.R.C., and (3) determined that P was subject to additions to tax under secs. 6651(a)(1), 6653(a)(1), and 6654, I.R.C. More than 2 years after R issued the notice of deficiency, P filed a 1988 return in which he reported the income from the 1988 information returns and listed deductions and dependency exemptions, which,…
1Opinion of the Court
FORTUNATO J. MENDES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Mendes v. Comm'r
No. 16032-95
United States Tax Court
121 T.C. 308; 2003 U.S. Tax Ct. LEXIS 40; 121 T.C. No. 19;
December 11, 2003, Filed
Respondent's adjustments to income and disallowance of deductions and dependency exemptions sustained. Respondent's imposition of 10-percent additional tax under sec. 72(t)(1), I.R.C., sustained. Respondent's imposition of additions to tax under secs. 6651(a)(1), 6653(a)(1), and 6654, I.R.C., sustained.
P has been continuously incarcerated since June 17, 1988. For P's 1988 taxable…
Also in this document: Concurrence · Swift; Concurrence · Vasquez; Concurrence · Goeke; Dissent.
2Cases cited53 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Griffin v. Oceanic Contractors, Inc.Supreme Court of the United States · 1982
- United States v. BoyleSupreme Court of the United States · 1985
- Dreicer v. CommissionerUnited States Tax Court · 1982
- Naftel v. CommissionerUnited States Tax Court · 1985
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