Powerstein v. Commissioner
United States Tax Court
R made a jeopardy assessment of deficiencies in Ps' Federal income tax for the taxable years 1984 through 1988 followed by the issuance of a notice of deficiency determining the same deficiencies. Ps filed a timely petition contesting R's determination.
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R made a jeopardy assessment of deficiencies in Ps' Federal income tax for the taxable years 1984 through 1988 followed by the issuance of a notice of deficiency determining the same deficiencies. Ps filed a timely petition contesting R's determination. R's answer contains allegations that the deficiency notice overstates Ps' reconstructed income for the taxable years 1984 and 1985 and understates Ps' reconstructed income for the taxable years 1986, 1987, and 1988. R's answer includes a claim for increased deficiencies for the taxable years 1986 through 1988. Subsequent to the filing of R's…
1Opinion of the Court
OPINION
Hamblen, Chief Judge:
This case was assigned to Chief Special Trial Judge Peter J. Panuthos pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.1 The Court agrees with and adopts the opinion of the Chief Special Trial Judge, which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
Panuthos, Chief Special Trial Judge:
Respondent determined deficiencies in and additions to the Federal income tax of Allen Powerstein and Rita Powerstein Rosen (petitioners) as follows:
Additions to tax
Year Deficiency Sec. 6653(b)(1) Sec. 6653(b)(2) Sec. 6661
$28,664 $14,374 CD CD T"t…
2Cases cited10 opinions
- Naftel v. CommissionerUnited States Tax Court · 1985
- Jasionowski v. CommissionerUnited States Tax Court · 1976
- Robert F. Koch and Evelyn C. Koch v. Donald C. Alexander, Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1977
- Meyer v. CommissionerUnited States Tax Court · 1991
- Powell v. CommissionerUnited States Tax Court · 1991
5 more not listed; retrieve them via the Exa API.
3Cited by24 opinions
- Colestock v. CommissionerUnited States Tax Court · 1994
- Ron Lykins, Inc. v. Comm'rUnited States Tax Court · 2009
- Phillips v. CommissionerUnited States Tax Court · 1996
- Powerstein v. Comm'rUnited States Tax Court · 2011
- RIPLEY v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 1994
19 more not listed; retrieve them via the Exa API.