Legal Opinion

Stringer v. Commissioner

United States Tax Court

Decided April 15, 1985No. Docket Nos. 26045-82, 3389-83PublishedCited by 86 opinions

Petitioners having failed to file a brief, after being directed by the Court to include therein "detailed findings of fact" based upon "specific, detailed, easily found and legible evidence," respondent filed a Motion for Entry of Default Judgment or Dismissal pursuant to Rule 123, Tax Court Rules of Practice and Procedure, with respect to issues upon which petitioners bear the burden of proof.

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Petitioners having failed to file a brief, after being directed by the Court to include therein "detailed findings of fact" based upon "specific, detailed, easily found and legible evidence," respondent filed a Motion for Entry of Default Judgment or Dismissal pursuant to Rule 123, Tax Court Rules of Practice and Procedure, with respect to issues upon which petitioners bear the burden of proof. Held, under the facts of this case and in the exercise of the Court's discretion, respondent's motion to dismiss those issues pursuant to Rule 123(b) will be granted. Held, further, amounts of…

1Opinion of the Court

Sterrett, Judge:

In these consolidated cases, respondent determined by separate notices of deficiency issued to each of petitioners and dated August 2, 1982, that petitioners Ronald Stringer and Andrea Stringer were liable for deficiencies in tax and additions to tax under sections 6651(a) and 6653(a), I.R.C. 1954, for the years 1978 and 1979 in docket No. 26045-82 in the following amounts:

Addition to tax

Petitioner Year Deficiency Sec. 6651(a) Sec. 6653(a)

Ronald Stringer 1978 $5,201 $387 $260

1979 6,410 427 321

Andrea Stringer 1978 271 14

1979 4,328 375 216

By separate notices of deficiency issued…

2Cases cited23 opinions

  1. Helvering v. MitchellSupreme Court of the United States · 1938
  2. Rowlee v. CommissionerUnited States Tax Court · 1983
  3. Gajewski v. CommissionerUnited States Tax Court · 1976
  4. Chris D. Stoltzfus and Irma H. Stoltzfus v. United StatesCourt of Appeals for the Third Circuit · 1968
  5. Grace M. Powell, of the Estate of O. E. Powell, Deceased v. Ralph C. Granquist, District Director of Internal RevenueCourt of Appeals for the Ninth Circuit · 1958

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3Cited by86 opinions

  1. Lunsford v. Comm'rUnited States Tax Court · 2001
  2. Calcutt v. CommissionerUnited States Tax Court · 1985
  3. Calcutt v. CommissionerUnited States Tax Court · 1988
  4. Basic Bible Church v. CommissionerUnited States Tax Court · 1986
  5. Churchill v. Comm'rUnited States Tax Court · 2011

81 more not listed; retrieve them via the Exa API.

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