Hannan v. Commissioner
United States Tax Court
Respondent mailed to petitioners a letter meeting all the formal requirements of a statutory notice of deficiency and notifying them that "income tax deficiencies" and additions to tax had been determined. The computations of tax due, contained in the statement attached to the letter, reflect no adjustments to petitioners' taxable income but refer to the self-employment tax less credits for estimated tax as "Deficiency of income tax."
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Respondent mailed to petitioners a letter meeting all the formal requirements of a statutory notice of deficiency and notifying them that "income tax deficiencies" and additions to tax had been determined. The computations of tax due, contained in the statement attached to the letter, reflect no adjustments to petitioners' taxable income but refer to the self-employment tax less credits for estimated tax as "Deficiency of income tax." Respondent moved to dismiss the petition on the ground that no "deficiency" exists. Held, respondent determined a deficiency in petitioners' income tax, and…
1Opinion of the Court
OPINION
FeatheRSton, Judge:
Respondent has filed a motion to dismiss the petition on the ground that the Court lacks jurisdiction. The decision turns on the application of sections 6211,6212,6213, and 6659.1 Specifically, the issue is whether the section 6651 additions to tax determined by respondent are “attributable to a deficiency” in petitioners’ income tax for 1959 to 1965, inclusive.
On December 27, 1968, respondent mailed a letter to petitioners notifying them of determinations of “income tax deficiencies” and additions to tax for late filing under section 6651(a). The letter — on the…
2Cases cited10 opinions
- Flora v. United StatesSupreme Court of the United States · 1960
- Ralph C. Granquist, District Director of Internal Revenue for the District of Oregon v. Margaret HacklemanCourt of Appeals for the Ninth Circuit · 1959
- O'MEARA v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1929
- United States v. Erie Forge Co.Court of Appeals for the Third Circuit · 1951
- Bowman v. CommissionerUnited States Tax Court · 1951
5 more not listed; retrieve them via the Exa API.
3Cited by94 opinions
- Naftel v. CommissionerUnited States Tax Court · 1985
- Howard S. Scar and Ethel M. Scar v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1987
- LTV Corp. v. CommissionerUnited States Tax Court · 1975
- Scar v. CommissionerUnited States Tax Court · 1983
- Estate of Young v. CommissionerUnited States Tax Court · 1983
89 more not listed; retrieve them via the Exa API.