Wellman v. Commissioner
United States Tax Court
Held, R's Motion to Dismiss Petition for Failure to State a Claim Upon Which Relief Can be Granted is granted. Held further, the Court, suasponte, awards damages to the United States in the amount of $5,000 since P instituted and maintained this proceeding primarily for delay and his position herein is groundless. Sec. 6673, I.R.C. 1954.
1Opinion of the Court
JAMES F. WELLMAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Wellman v. Commissioner
Docket No. 39758-84.
United States Tax Court
T.C. Memo 1985-97; 1985 Tax Ct. Memo LEXIS 538; 49 T.C.M. (CCH) 866; T.C.M. (RIA) 85097;
March 4, 1985.
Held, R's Motion to Dismiss Petition for Failure to State a Claim Upon Which Relief Can be Granted is granted. Held further, the Court, suasponte, awards damages to the United States in the amount of $5,000 since P instituted and maintained this proceeding primarily for delay and his position herein is groundless. Sec. 6673, I.R.C. 1954.
James F.…
2Cases cited40 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
- James v. United StatesSupreme Court of the United States · 1961
- Rowlee v. CommissionerUnited States Tax Court · 1983
- Greenberg's Express, Inc. v. CommissionerUnited States Tax Court · 1974
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