Galuska v. Commissioner
United States Tax Court
P had not filed a Form 1040, U.S. Individual Income Tax Return, for 1986 nor a claim for credit or refund of 1986 tax as of the date of mailing of a deficiency notice to him, Apr. 12, 1990. P actually overpaid his 1986 tax through withholding and a $ 20,000 estimated tax payment made when filing a Form 4868, Application for Automatic Extension of Time to File U.S.
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P had not filed a Form 1040, U.S. Individual Income Tax Return, for 1986 nor a claim for credit or refund of 1986 tax as of the date of mailing of a deficiency notice to him, Apr. 12, 1990. P actually overpaid his 1986 tax through withholding and a $ 20,000 estimated tax payment made when filing a Form 4868, Application for Automatic Extension of Time to File U.S. Individual Income Tax Return, on Apr. 15, 1987. P subsequently filed a Form 2688, Application for Additional Extension of Time to File U.S. Individual Income Tax Return, on Aug. 15, 1987, to extend his time to file to Oct. 15, 1987.…
1Opinion of the Court
Parker, Judge:
By statutory notice of deficiency dated April 12, 1990, respondent determined a deficiency in petitioner's Federal income tax for the taxable year 1986 in the amount of $96,144 and additions to tax as follows:
Sec. 6651(a)(1) Sec. 6653(a)(1)(A) Sec. 6654(a)
$18,153 1$4,807 $3,229
Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the relevant period, and all Rule references are to the Tax Court Rules of Practice and Procedure.
After concessions,1 the issue remaining for decision is whether or not petitioner is entitled to an overpayment…
2Cases cited14 opinions
- Badaracco v. CommissionerSupreme Court of the United States · 1984
- Beard v. Comm'rUnited States Tax Court · 1984
- Florsheim Brothers Drygoods Co. v. United StatesSupreme Court of the United States · 1930
- Commissioner v. Lane-Wells Co.Supreme Court of the United States · 1944
- Zellerbach Paper Co. v. HelveringSupreme Court of the United States · 1934
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3Cited by29 opinions
- Commissioner v. LundySupreme Court of the United States · 1996
- Allen v. CommissionerUnited States Tax Court · 1992
- Risman v. CommissionerUnited States Tax Court · 1993
- Patronik-Holder v. CommissionerUnited States Tax Court · 1993
- Bergersen v. CommissionerUnited States Tax Court · 1995
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