Legal Opinion

Grimes v. Commissioner

United States Tax Court

Decided February 6, 1984No. Docket No. 744-83PublishedCited by 29 opinions

Petitioner filed a petition in this Court claiming that his wages are not taxable income. He had previously filed a similar petition and was informed by this Court that his contentions were without merit. Held, respondent's determination of deficiencies and additions to tax under secs. 6651(a), 6653(a), and 6654(a), I.R.C. 1954, are sustained.

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Petitioner filed a petition in this Court claiming that his wages are not taxable income. He had previously filed a similar petition and was informed by this Court that his contentions were without merit. Held, respondent's determination of deficiencies and additions to tax under secs. 6651(a), 6653(a), and 6654(a), I.R.C. 1954, are sustained. Held, further, damages under sec. 6673, I.R.C. 1954, are awarded to the United States because petitioner instituted these proceedings primarily for delay, and his position is frivolous.

1Opinion of the Court

OPINION

Fay, Judge:

Respondent determined deficiencies in and additions to petitioner’s Federal income tax as follows:

Year Deficiency Sec. 6651(a)1 addition to tax Sec. 6653(a) addition to tax Sec. 6654(a) addition to tax

1977 $7,102.00 $1,775.50 $355.10 $227.26

1979 6,969.12 1,742.28 348.46 292.70

1980 4,949.48 1,237.37 247.47 316.76

The issues are (1) whether wages received by petitioner constitute gross income under section 61(a);2 (2) whether petitioner is liable for additions to tax under section 6651(a); (3) whether petitioner is liable for additions to tax under section 6653(a); (4) whether…

2Cases cited7 opinions

  1. Rowlee v. CommissionerUnited States Tax Court · 1983
  2. Enoch v. CommissionerUnited States Tax Court · 1972
  3. Wilkinson v. CommissionerUnited States Tax Court · 1979
  4. Hatfield v. CommissionerUnited States Tax Court · 1977
  5. Fischer v. CommissionerUnited States Tax Court · 1968

2 more not listed; retrieve them via the Exa API.

3Cited by29 opinions

  1. Beard v. Comm'rUnited States Tax Court · 1984
  2. Cabirac v. Comm'rUnited States Tax Court · 2003
  3. John A. Grimes v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1986
  4. Spurlock v. Comm'rUnited States Tax Court · 2003
  5. Richard D. May v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1985

24 more not listed; retrieve them via the Exa API.

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