Todd v. Commissioner
United States Tax Court
Deficiencies determined by respondent were sustained because petitioners' property was not placed in service during the years in issue. Valuation of the property was also overstated on the return by more than 250 percent of the correct valuation. Held, the underpayments of petitioners' taxes were not "attributable to" the valuation overstatement, and additions to tax under sec. 6659, I.R.C. 1954, as amended, do not apply for the years in issue.
1Opinion of the Court
OPINION
COHEN, Judge:
In Noonan v. Commissioner, T.C. Memo. 1986-449, we found that petitioners Richard J. Todd and Denese W. Todd (the Todds) purchased two FoodSource containers by agreements dated December 8, 1981, and a third container by an agreement dated October 14, 1982. The Todds’ containers were, however, the subject of a dispute between the seller, FoodSource, Inc., and the manufacturer, Budd Co., and were not released to the Todds or placed in service prior to November 29, 1983. The issue for decision here is whether the Todds are hable for additions to tax under section 6659.1
The…
2Cases cited13 opinions
- Rose v. CommissionerUnited States Tax Court · 1987
- Solowiejczyk v. CommissionerUnited States Tax Court · 1985
- Estate of Baron v. CommissionerUnited States Tax Court · 1984
- Estate of Sydney S. Baron, Sylvia S. Baron, Administratrix, and Sylvia S. Baron v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1986
- Zirker v. CommissionerUnited States Tax Court · 1986
8 more not listed; retrieve them via the Exa API.
3Cited by108 opinions
- Rybak v. CommissionerUnited States Tax Court · 1988
- Richard J. Todd and Denese W. Todd v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1988
- McCrary v. CommissionerUnited States Tax Court · 1989
- Krause v. CommissionerUnited States Tax Court · 1992
- Petaluma FX Partners, LLC v. Comm'rUnited States Tax Court · 2008
103 more not listed; retrieve them via the Exa API.