Spurlock v. Comm'r
United States Tax Court
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
- Welch v. HelveringSupreme Court of the United States · 1933
- HIGBEE v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001
- United States v. BoyleSupreme Court of the United States · 1985
- Grosshandler v. CommissionerUnited States Tax Court · 1980
- Johnny Weimerskirch v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1979
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3Cited by41 opinions
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- Mooney v. Comm'rUnited States Tax Court · 2011
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