Coulter v. Commissioner
United States Tax Court
Petitioner instituted this proceeding but refused to participate in the Court's stipulation procedures under Rule 91, Tax Court Rules of Practice and Procedure, or to produce any evidence in regard to the itemized deductions and business loss claimed on his returns. As he had done in his earlier case in this Court, petitioner again raised frivolous arguments under the Fourth and Fifth Amendments to the United States Constitution.
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Petitioner instituted this proceeding but refused to participate in the Court's stipulation procedures under Rule 91, Tax Court Rules of Practice and Procedure, or to produce any evidence in regard to the itemized deductions and business loss claimed on his returns. As he had done in his earlier case in this Court, petitioner again raised frivolous arguments under the Fourth and Fifth Amendments to the United States Constitution. Held, respondent's determinations of income tax deficiencies and additions to the tax under secs. 6651(a) and 6653(a), I.R.C. 1954, are sustained. Held, further, on…
1Opinion of the Court
OPINION
Parker, Judge:
Respondent determined deficiencies in and additions to petitioners’ Federal income tax for their 1979 and 1980 taxable years as follows:
Additions to tax
Year Deficiency Sec. 6651(a)1 Sec. 6653(a)
$592.00 $29.60 $282.35 H* CO <3 CO
4,925.72 0 246.28 h-i C£> CO O
The issues for decision are (1) whether petitioners are entitled to itemized deductions in 1979 and 1980 in an amount exceeding those allowed by respondent; (2) whether petitioners are entitled to a claimed business loss for their 1980 taxable year; (3) whether petitioners are liable for self-employment tax for their…
2Cases cited21 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Roberts v. CommissionerUnited States Tax Court · 1974
- Wilkinson v. CommissionerUnited States Tax Court · 1979
- William H. And Avilda L. Edwards v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1982
- McCoy v. CommissionerUnited States Tax Court · 1981
16 more not listed; retrieve them via the Exa API.
3Cited by55 opinions
- Richard D. May v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1985
- Masters v. CommissionerUnited States Tax Court · 1994
- Nunn v. Comm'rUnited States Tax Court · 2002
- Davenport v. CommissionerUnited States Tax Court · 1989
- Scruggs v. CommissionerUnited States Tax Court · 1995
50 more not listed; retrieve them via the Exa API.