Williams v. Commissioner
United States Tax Court
P mailed two Forms 1040, U.S. Individual Income Tax Return, for 1991 to the IRS. The first Form 1040 included a deduction for "Non Taxable Compensation" equal to P's total income, and P failed to sign it. P stipulated that this Form 1040 is not a valid return.
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P mailed two Forms 1040, U.S. Individual Income Tax Return, for 1991 to the IRS. The first Form 1040 included a deduction for "Non Taxable Compensation" equal to P's total income, and P failed to sign it. P stipulated that this Form 1040 is not a valid return. In the second Form 1040, P reported taxes owed of $ 36,621. P however attached a disclaimer statement to the second Form 1040 stating that he denied all tax liability and did not admit that the stated amount of tax was due. HELD: P is liable for the deficiency. HELD, FURTHER, P's second Form 1040 is not a valid return; therefore, P is…
1Opinion of the Court
STEPHEN W. WILLIAMS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Williams v. Commissioner
No. 23179-97
United States Tax Court
114 T.C. 136; 2000 U.S. Tax Ct. LEXIS 9; 114 T.C. No. 8;
March 1, 2000, Filed
Decision will be entered under Rule 155.
P mailed two Forms 1040, U.S. Individual Income Tax Return,
for 1991 to the IRS. The first Form 1040 included a deduction
for "Non Taxable Compensation" equal to P's total income, and P
failed to sign it. P stipulated that this Form 1040 is not a
valid return. In the second Form 1040, P reported taxes owed of
$ 36,621. P however attached a…
2Cases cited25 opinions
- United States v. BoyleSupreme Court of the United States · 1985
- Eisner v. MacOmberSupreme Court of the United States · 1920
- Eisner, Internal Revenue Collector v. MacOmberSupreme Court of the United States · 1919
- Badaracco v. CommissionerSupreme Court of the United States · 1984
- Cupp v. CommissionerUnited States Tax Court · 1975
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