Sanders v. Comm'r
United States Tax Court
D was a U.S. citizen who built his own company in the United States to both manufacture and distribute surge suppression devices. In 2002 D signed an employment agreement to work for M, an LP organized in the U.S.Virgin Islands (USVI), as a professional consultant. The employment agreement required D to become a resident of the USVI. Pursuant to I.R.C. sec. 932(c)(2), D filed Forms 1040, U.S.
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D was a U.S. citizen who built his own company in the United States to both manufacture and distribute surge suppression devices. In 2002 D signed an employment agreement to work for M, an LP organized in the U.S.Virgin Islands (USVI), as a professional consultant. The employment agreement required D to become a resident of the USVI. Pursuant to I.R.C. sec. 932(c)(2), D filed Forms 1040, U.S. Individual Income Tax Return, with the USVI Bureau of Internal Revenue (VIBIR) for tax years 2002, 2003, and 2004. More than three years after D filed Forms 1040 with the VIBIR, R mailed D a notice of…
1Opinion of the Court
Kerrigan, Judge-.
Respondent determined the following deficiencies and additions to tax with respect to tax years 2002, 2003, and 2004:
Additions to tax
Year Deficiency Sec. 6651(a)(1) Sec. 6651(a)(2) Sec. 6654
2002 $485,805 $98,821 $109,801 $1,667
2003 106,758 24,021 26,690 2,754
2004 54,648 12,296 13,662 1,566
Unless otherwise indicated, all section references are to the Internal Revenue Code (Code) in effect for the years in issue. We round all monetary amounts to the nearest dollar.
The threshold issue for consideration is whether the section 6501 period of limitations on assessment and…
2Cases cited22 opinions
- Beard v. Comm'rUnited States Tax Court · 1984
- Florsheim Brothers Drygoods Co. v. United StatesSupreme Court of the United States · 1930
- Zellerbach Paper Co. v. HelveringSupreme Court of the United States · 1934
- Robert D. Beard v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1986
- Lucas v. Pilliod Lumber Co.Supreme Court of the United States · 1930
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3Cited by5 opinions
- Commissioner of IRS v. Estate of Travis L. SandersCourt of Appeals for the Eleventh Circuit · 2016
- Smith v. United States Internal Revenue Service (In Re Smith)Court of Appeals for the Ninth Circuit · 2016
- Acone v. Comm'rUnited States Tax Court · 2017
- Melissa Coffey Hulett a.k.a. Melissa Coffey v. CommissionerUnited States Tax Court · 2018
- Sanders v. Comm'rUnited States Tax Court · 2015