Sloan v. Commissioner
United States Tax Court
P failed to file returns for 1981, 1982, and 1983 and was convicted of tax evasion for those years. Thereafter, he filed a petition in this Court with respect to the same years. Approximately 1 month prior to trial, Forms 1040 were submitted to IRS for the years in issue. The forms reported P's wage income and tax thereon and claimed joint filing status.
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P failed to file returns for 1981, 1982, and 1983 and was convicted of tax evasion for those years. Thereafter, he filed a petition in this Court with respect to the same years. Approximately 1 month prior to trial, Forms 1040 were submitted to IRS for the years in issue. The forms reported P's wage income and tax thereon and claimed joint filing status. P and W signed the Forms 1040. Immediately after the preprinted jurat and just above their signatures, they inserted the words "Denial & Disclaimer attached as part of this Form." Attached to each Form 1040 was a statement entitled "DENIAL…
1Opinion of the Court
Ruwe, Judge-.
Respondent determined deficiencies in petitioner’s Federal income taxes and additions to tax as follows:
Additions to tax
Sec. Sec. Sec. Year Deficiency 6653(b)(1)1 6653(b)(2) 6654
$4,694.50 $613.40 jD 00 CO rH 00 oo rH
4,047.00 50 percent of the interest due on $8,094 788.C3 00 CO ^ Cq 00 a iH
1983 11,450 5,725.00 50 percent of the interest due on $6,624.43 331.51
After concessions, the only issues remaining for decision are: (1) Whether petitioner is entitled to compute his tax using the rates for persons filing joint returns, and (2) whether this Court should impose a penalty on…
2Cases cited22 opinions
- Cupp v. CommissionerUnited States Tax Court · 1975
- Beard v. Comm'rUnited States Tax Court · 1984
- Commissioner v. Lane-Wells Co.Supreme Court of the United States · 1944
- United States v. Arthur J. PorthCourt of Appeals for the Tenth Circuit · 1970
- Robert D. Beard v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1986
17 more not listed; retrieve them via the Exa API.
3Cited by24 opinions
- Davis v. CommissionerUnited States Tax Court · 2000
- Williams v. CommissionerUnited States Tax Court · 2000
- Berger v. CommissionerUnited States Tax Court · 1996
- Diamond v. StatesUnited States Court of Federal Claims · 2012
- Waltner v. Comm'rUnited States Tax Court · 2014
19 more not listed; retrieve them via the Exa API.