Legal Opinion

Spurlock v. Comm'r

United States Tax Court

Decided April 29, 2003No. 6438-01UnpublishedCited by 41 opinions

P did not file Federal income tax returns for 1995, 1996, and 1997. R issued a notice of deficiency in which he determined that P received wages, nonemployee compensation, and distributions from individual retirement plans for each of the years. R based his determinations on third-party information returns.

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P did not file Federal income tax returns for 1995, 1996, and 1997. R issued a notice of deficiency in which he determined that P received wages, nonemployee compensation, and distributions from individual retirement plans for each of the years. R based his determinations on third-party information returns. Held: Various third-party records that R offered in support of his determinations are admissible evidence under rules 803(6) and 902(11) of the Federal Rules of Evidence, which allow the introduction of records of a regularly conducted activity if, inter alia, the records are accompanied…

1Opinion of the Court

GLORIA J. SPURLOCK, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Spurlock v. Comm'r

No. 6438-01

United States Tax Court

T.C. Memo 2003-124; 2003 Tax Ct. Memo LEXIS 123; 85 T.C.M. (CCH) 1236;

April 29, 2003, Filed

Spurlock v. Comm'r, 118 T.C. 155, 2002 U.S. Tax Ct. LEXIS 9 (2002)

An appropriate order will be issued denying petitioner's motion in limine, and a decision will be entered for respondent except for the additions to tax under section 6651(a)(2), which do not apply.

P did not file Federal income tax returns for 1995, 1996,

and 1997. R issued a notice of deficiency in which he…

2Cases cited22 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. HIGBEE v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001
  3. United States v. BoyleSupreme Court of the United States · 1985
  4. Grosshandler v. CommissionerUnited States Tax Court · 1980
  5. Johnny Weimerskirch v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1979

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

3Cited by41 opinions

  1. United States v. Fred S. PangCourt of Appeals for the Ninth Circuit · 2004
  2. Swanson v. Comm'rUnited States Tax Court · 2003
  3. Rader v. CommissionerUnited States Tax Court · 2014
  4. Adler v. Comm'rUnited States Tax Court · 2010
  5. Mooney v. Comm'rUnited States Tax Court · 2011

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

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