Andrews v. Commissioner
United States Tax Court
Ps filed a document purporting to be their 1995 Federal income tax return; Ps' so-called return was filed on plain sheets of paper. The IRS did not process the document as a return because it did not include sufficient information. R determined an income tax deficiency, an addition to tax under sec. 6651(a)(1), I.R.C., and an accuracy-related penalty under sec. 6662(a), I.R.C., for the 1995 taxable year.
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Ps filed a document purporting to be their 1995 Federal income tax return; Ps' so-called return was filed on plain sheets of paper. The IRS did not process the document as a return because it did not include sufficient information. R determined an income tax deficiency, an addition to tax under sec. 6651(a)(1), I.R.C., and an accuracy-related penalty under sec. 6662(a), I.R.C., for the 1995 taxable year. Ps have conceded the deficiency and addition to tax under sec. 6651(a)(1), I.R.C., as determined by R. Held: Ps' putative return of tax not filed on the proper form prescribed by the…
1Opinion of the Court
RICHARD ANDREWS AND L. SCOTT-ANDREWS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Andrews v. Commissioner
No. 12628-98
United States Tax Court
T.C. Memo 1999-281; 1999 Tax Ct. Memo LEXIS 321; 78 T.C.M. (CCH) 345; T.C.M. (RIA) 99281;
August 24, 1999, Filed
Decision will be entered under Rule 155.
Ps filed a document purporting to be their 1995 Federal
income tax return; Ps' so-called return was filed on plain
sheets of paper. The IRS did not process the document as a
return because it did not include sufficient information. R
determined an income tax deficiency, an addition to tax under
sec…
2Cases cited9 opinions
- Beard v. Comm'rUnited States Tax Court · 1984
- Commissioner v. Lane-Wells Co.Supreme Court of the United States · 1944
- Zellerbach Paper Co. v. HelveringSupreme Court of the United States · 1934
- Robert D. Beard v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1986
- Parker v. CommissionerCourt of Appeals for the Eighth Circuit · 1966
4 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Williams v. CommissionerUnited States Tax Court · 2000