Dixon v. Commissioner
United States Tax Court
Ps were criminally prosecuted for failure to file individual income tax returns for 1992-95. At the time, Ps were owners, officers, and employees of Tryco Corp., which failed to file employment tax returns and corporate income tax returns during this period.
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Ps were criminally prosecuted for failure to file individual income tax returns for 1992-95. At the time, Ps were owners, officers, and employees of Tryco Corp., which failed to file employment tax returns and corporate income tax returns during this period. As part of a plea agreement with the Department of Justice, Ps agreed that their wrongdoing had inflicted a "tax loss" on the IRS of $61,021 and acknowledged that they could be required to make restitution of this amount. On advice of their attorney they transferred funds to Tryco with instructions that Tryco remit the funds to the IRS.…
1Opinion of the Court
JAMES R. DIXON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent;
SHARON C. DIXON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Dixon v. Comm'r
Docket Nos. 9962-05L, 9965-05L.
United States Tax Court
141 T.C. 173; 2013 U.S. Tax Ct. LEXIS 23; 141 T.C. No. 3;
September 3, 2013, Filed
Dixon v. Comm'r, T.C. Memo 2013-207, 2013 Tax Ct. Memo LEXIS 216 (T.C., 2013)
Appropriate decisions will be entered.
Ps were criminally prosecuted for failure to file individual income tax returns for 1992-95. At the time, Ps were owners, officers, and employees of Tryco Corp., which failed to file…
Also in this document: Concurrence; Dissent · Holmes; Dissent · Buch.
2Cases cited49 opinions
- Parklane Hosiery Co. v. ShoreSupreme Court of the United States · 1979
- Goza v. CommissionerUnited States Tax Court · 2000
- Old Colony Trust Co. v. CommissionerSupreme Court of the United States · 1929
- Sego v. CommissionerUnited States Tax Court · 2000
- Flora v. United StatesSupreme Court of the United States · 1960
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