Legal Opinion

Andrews v. Commissioner

United States Tax Court

Decided August 24, 1999No. 12628-98UnpublishedCited by 1 opinion

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

  1. Beard v. Comm'rUnited States Tax Court · 1984
  2. Commissioner v. Lane-Wells Co.Supreme Court of the United States · 1944
  3. Zellerbach Paper Co. v. HelveringSupreme Court of the United States · 1934
  4. Robert D. Beard v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1986
  5. Parker v. CommissionerCourt of Appeals for the Eighth Circuit · 1966

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

3Cited by1 opinion

  1. Williams v. CommissionerUnited States Tax Court · 2000

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