Estate of McClanahan v. Commissioner
United States Tax Court
Petitioners failed to timely file their Federal income tax returns for each of the years 1977 through 1983. Petitioner husband was in poor health but actively operated his accounting and tax practice.
Read the full summary
Petitioners failed to timely file their Federal income tax returns for each of the years 1977 through 1983. Petitioner husband was in poor health but actively operated his accounting and tax practice. After being contacted by an IRS special agent in April 1984, petitioner husband prepared and filed delinquent returns for all years in question on June 1, 1984. Both the taxes due and additions to tax under sec. 6651(a)(1), I.R.C. 1954, were paid by check dated July 23, 1984. Held: 1. The deteriorating health of petitioner husband in these circumstances does not excuse the imposition of…
1Opinion of the Court
JACOBS, Judge:
Respondent determined the following additions to petitioners’ Federal income taxes:
Additions to tax
Year Sec. 6651(a)(1)1 See. 6653(a) Sec. 6653(a)(1) Sec. 66612 Si 3 té <&> CO
1977 $406
1978 $3,831 766
1979 1,337 267
1980 5,592 1,118
1981 $448 *
1982 12,372 2,474 $12,372
1983 1,424 285 1,424
The issues remaining for decision are: (1) Whether petitioners are hable for the section 6653(a) additions to tax for negligence or intentional disregard of rules or regulations; and (2) whether petitioners are hable for the section 6661 additions to tax in 1982 and 1983 for substantial…
2Cases cited14 opinions
- Carlos and Jacqueline Marcello v. Commissioner of Internal Revenue, Joseph, Jr. And Anastasia Marcello v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1967
- Enoch v. CommissionerUnited States Tax Court · 1972
- Pallottini v. CommissionerUnited States Tax Court · 1988
- Commissioner v. AckerSupreme Court of the United States · 1959
- Marcello v. CommissionerUnited States Tax Court · 1964
9 more not listed; retrieve them via the Exa API.
3Cited by14 opinions
- Hesselink v. CommissionerUnited States Tax Court · 1991
- Glenny A. Lazore, Carol L. Lazore v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Third Circuit · 1993
- Cramer v. CommissionerUnited States Tax Court · 1993
- Mauerman v. CommissionerUnited States Tax Court · 1993
- Fisher v. CommissionerUnited States Tax Court · 1992
9 more not listed; retrieve them via the Exa API.