Espinosa v. Commissioner
United States Tax Court
P, a nonresident alien individual, failed to file Federal income tax returns for the years 1987 through 1991. R repeatedly notified P of his failure to file. R prepared substitute returns for P and notified P that pursuant to sec. 874(a), I.R.C., no deductions were allowable. P subsequently submitted returns claiming the benefit of deductions. R then issued a notice of deficiency.
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P, a nonresident alien individual, failed to file Federal income tax returns for the years 1987 through 1991. R repeatedly notified P of his failure to file. R prepared substitute returns for P and notified P that pursuant to sec. 874(a), I.R.C., no deductions were allowable. P subsequently submitted returns claiming the benefit of deductions. R then issued a notice of deficiency. Held: P is not entitled to the benefit of deductions pursuant to sec. 874(a), I.R.C.Held, further, P is liable for additions to tax pursuant to secs. 6651(a)(1) and 6654, I.R.C.
1Opinion of the Court
GUILLERMO BAEZ ESPINOSA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Espinosa v. Commissioner
Docket No. 8900-94.
United States Tax Court
107 T.C. 146; 1996 U.S. Tax Ct. LEXIS 40; 107 T.C. No. 9;
September 24, 1996, Filed
Decision will be entered under Rule 155.
P, a nonresident alien individual, failed to file Federal income tax returns for the years 1987 through 1991. R repeatedly notified P of his failure to file. R prepared substitute returns for P and notified P that pursuant to sec. 874(a), I.R.C., no deductions were allowable. P subsequently submitted returns claiming the…
2Cases cited14 opinions
- Mailman v. CommissionerUnited States Tax Court · 1988
- Brittingham v. CommissionerUnited States Tax Court · 1976
- Blenheim Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1942
- Taylor Secur., Inc. v. CommissionerUnited States Board of Tax Appeals · 1939
- Ardbern Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1941
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