Legal Opinion

Shaw v. Comm'r

United States Tax Court

Decided April 18, 2003No. 7752-00Unpublished

1Opinion of the Court

CHARLES SHAW, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Shaw v. Comm'r

No. 7752-00

United States Tax Court

T.C. Memo 2003-111; 2003 Tax Ct. Memo LEXIS 110; 85 T.C.M. (CCH) 1179; T.C.M. (RIA) 55119;

April 18, 2003, Filed

Respondent's determination as to unreported income sustained. Petitioner was not liable for fraud penalty for 1993, 1994, or 1995. Petitioner was liable for accuracy-related penalty for 1993-95. Court concluded that statute of limitations did not bar assessment of tax for 1993.

A. Albert Ajubita and Wanda L. Theriot, for petitioner.

Emile L. Hebert III, for respondent.

2Cases cited38 opinions

  1. Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
  2. Wichita Term. El. Co. v. Commissioner of Int. R.Court of Appeals for the Tenth Circuit · 1947
  3. Otsuki v. CommissionerUnited States Tax Court · 1969
  4. Bolen Webb and Cornelia Webb v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1968
  5. Vanicek v. CommissionerUnited States Tax Court · 1985

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