Dees v. Comm'r
United States Tax Court
P claimed a refundable credit under I.R.C. sec. 36B on his 2014 income tax return. R determined that P was not entitled to the refundable credit and issued a notice of deficiency to P. That notice showed a deficiency of zero on the first page. The attached computation pages stated that there was a decrease to refundable credits but erroneously computed a tax deficiency of ".00". P timely filed a petition to challenge R's disallowance of his refundable credit.
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P claimed a refundable credit under I.R.C. sec. 36B on his 2014 income tax return. R determined that P was not entitled to the refundable credit and issued a notice of deficiency to P. That notice showed a deficiency of zero on the first page. The attached computation pages stated that there was a decrease to refundable credits but erroneously computed a tax deficiency of ".00". P timely filed a petition to challenge R's disallowance of his refundable credit. The Court ordered R to show cause why this case should not be dismissed for lack of jurisdiction, questioning the validity of the…
1Opinion of the Court
TIMOTHY M. DEES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Dees v. Comm'r
Docket No. 29397-15
United States Tax Court
2017 U.S. Tax Ct. LEXIS 2; 148 T.C. No. 1; 113 T.C.M. (CCH) 3905;
February 2, 2017, Filed
An appropriate order will be issued.
P claimed a refundable credit under I.R.C. sec. 36B on his 2014 income tax return. R determined that P was not entitled to the refundable credit and issued a notice of deficiency to P. That notice showed a deficiency of zero on the first page. The attached computation pages stated that there was a decrease to refundable credits but…
Also in this document: Concurrence; Dissent · Foley; Dissent · Gustafson.
2Cases cited63 opinions
- Phillips v. CommissionerSupreme Court of the United States · 1931
- Naftel v. CommissionerUnited States Tax Court · 1985
- Greenberg's Express, Inc. v. CommissionerUnited States Tax Court · 1974
- Commissioner v. Gooch Milling & Elevator Co.Supreme Court of the United States · 1944
- Jarvis v. CommissionerUnited States Tax Court · 1982
58 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
- First Rock Baptist Church Child Dev. Ctr. v. Comm'rUnited States Tax Court · 2017
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- Schussel v. Comm'rUnited States Tax Court · 2017