Wilson v. Comm'r
United States Tax Court
In conjunction with a criminal prosecution for tax evasion, P executed a Plea Agreement in which he agreed to file delinquent Federal income tax returns and report specific amounts of income. After assessing the tax liabilities reported on the delinquent returns, R sent P a notice of deficiency determining only additions to tax for fraudulent failure to file and failure to pay estimated tax under secs. 6651(f) and 6654(a), I.R.C., respectively.
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In conjunction with a criminal prosecution for tax evasion, P executed a Plea Agreement in which he agreed to file delinquent Federal income tax returns and report specific amounts of income. After assessing the tax liabilities reported on the delinquent returns, R sent P a notice of deficiency determining only additions to tax for fraudulent failure to file and failure to pay estimated tax under secs. 6651(f) and 6654(a), I.R.C., respectively. P filed a petition for redetermination. R moved to dismiss for lack of jurisdiction, arguing that the deficiency notice was invalid because R had not…
1Opinion of the Court
OPINION
DAWSON, Judge:
This case was assigned to Special Trial Judge Robert N. Armen, Jr., pursuant to the provisions of section 7443A(b)(5) and Rules 180, 181, and 183.1 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
Armen, Special Trial Judge:
This matter is before the Court on respondent’s motion to dismiss for lack of jurisdiction. Respondent asserts that jurisdiction is lacking because “no deficiency is raised in the notice of deficiency, pursuant to I.R.C. sections 6211 and 6665, nor has respondent made…
2Cases cited7 opinions
- Naftel v. CommissionerUnited States Tax Court · 1985
- Monge v. CommissionerUnited States Tax Court · 1989
- Normac, Inc. v. CommissionerUnited States Tax Court · 1988
- Estate of Di Rezza v. CommissionerUnited States Tax Court · 1982
- Meyer v. CommissionerUnited States Tax Court · 1991
2 more not listed; retrieve them via the Exa API.
3Cited by5 opinions
- Gray v. CommissionerCourt of Appeals for the Seventh Circuit · 2013
- Dixon v. Commissioner of Internal Revenue ServiceDistrict Court, N.D. Illinois · 2018
- HORN v. COMMISSIONERUnited States Tax Court · 2002
- Richard A. Wilson v. CommissionerUnited States Tax Court · 2002
- Wilson v. Comm'rUnited States Tax Court · 2002