Thurner v. Comm'r
United States Tax Court
On Jan. 30, 1991, the Court entered a decision in docket No. 8407-87 redetermining Ps' joint tax liabilities for 1980 and 1981. In June 1991, R assessed the taxes, additions to tax, and increased interest as set forth in the above-referenced decision. Ps' joint tax liability for 1980 was fully paid as of May 4, 1992. A portion of Ps' joint tax liability for 1981 remained unpaid as of the dates the petitions were filed in these cases.
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On Jan. 30, 1991, the Court entered a decision in docket No. 8407-87 redetermining Ps' joint tax liabilities for 1980 and 1981. In June 1991, R assessed the taxes, additions to tax, and increased interest as set forth in the above-referenced decision. Ps' joint tax liability for 1980 was fully paid as of May 4, 1992. A portion of Ps' joint tax liability for 1981 remained unpaid as of the dates the petitions were filed in these cases. On Dec. 2, 1991, Ps filed a joint Federal income tax return for 1990 reporting tax due. No remittance was made with this return. Ps submitted a delinquent joint…
1Opinion of the Court
OPINION
Cohen, Judge:
This case was assigned to Chief Special Trial Judge Peter J. Panuthos, 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 Chief Special Trial Judge, which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
Panuthos, Chief Special Trial Judge:
These consolidated cases are before the Court on respondent’s motions for summary judgment, as supplemented, filed pursuant to Rule 121. As explained in detail below, we shall grant respondent’s motion for summary judgment, as supplemented, as to…
2Cases cited17 opinions
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
- Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
- Naftel v. CommissionerUnited States Tax Court · 1985
- Florida Peach Corp. v. CommissionerUnited States Tax Court · 1988
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3Cited by11 opinions
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- Leonard W. Harbin, and Bernice Nalls, Intervenor v. CommissionerUnited States Tax Court · 2011
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