Legal Opinion

Reiff v. Commissioner

United States Tax Court

Decided November 30, 1981No. Docket No. 15778-79PublishedCited by 192 opinions

Petitioners filed a 32-page preprinted document with respondent. The Form 1040 portion of this document was signed under penalties of perjury. On the document, petitioners disclosed their names, address, and social security numbers, petitioner-husband's occupation, Federal income tax withheld, and estimated tax payments; they also asserted a variety of constitutional objections.

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Petitioners filed a 32-page preprinted document with respondent. The Form 1040 portion of this document was signed under penalties of perjury. On the document, petitioners disclosed their names, address, and social security numbers, petitioner-husband's occupation, Federal income tax withheld, and estimated tax payments; they also asserted a variety of constitutional objections. Attached to this document was petitioner-husband's Form W-2, which contained a hand-written notation to the effect that the amounts shown thereon are Federal Reserve Notes. Held: 1. Petitioners are liable for an…

1Opinion of the Court

Chabot, Judge:

Respondent determined a deficiency in Federal individual income tax against petitioners for 1977 in the amount of $740. In his answer, respondent asserts under section 6214(a)1 that the deficiency in income tax should be increased by $1,471 (for a total of $2,211) and that additions to tax should be imposed under sections 6651(a)(1) (failure to file return) and 6653(a) (negligence) in the amounts of $274.75 and $110.55, respectively.2

The issues for decision are:(1) Whether petitioners are liable for an income tax deficiency;,(2) Whether petitioners are liable for an addition to…

2Cases cited28 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Commissioner v. DubersteinSupreme Court of the United States · 1960
  3. Old Colony Trust Co. v. CommissionerSupreme Court of the United States · 1929
  4. Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
  5. Cupp v. CommissionerUnited States Tax Court · 1975

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

3Cited by192 opinions

  1. Beard v. Comm'rUnited States Tax Court · 1984
  2. Hebrank v. CommissionerUnited States Tax Court · 1983
  3. Jarvis v. CommissionerUnited States Tax Court · 1982
  4. Davis v. CommissionerUnited States Tax Court · 1983
  5. Gefen v. CommissionerUnited States Tax Court · 1986

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

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