Legal Opinion

Thompson v. Commissioner

United States Tax Court

Decided April 8, 1982No. Docket Nos. 15111-80, 15112-80PublishedCited by 99 opinions

Petitioners filed a Form 1040 for 1976 and Forms 1040A for 1977 and 1978. Each form contains petitioners' names, address, social security numbers, occupations, and signatures. On the 1976 Form 1040, petitioners entered an amount as having been withheld for Federal income taxes. On each of the forms, petitioners claimed three exemptions and designated their filing status as "Married filing joint return."

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Petitioners filed a Form 1040 for 1976 and Forms 1040A for 1977 and 1978. Each form contains petitioners' names, address, social security numbers, occupations, and signatures. On the 1976 Form 1040, petitioners entered an amount as having been withheld for Federal income taxes. On each of the forms, petitioners claimed three exemptions and designated their filing status as "Married filing joint return." The remaining entries on the forms consist of the words "Object: Self-incrimination" or "None." Respondent issued a separate notice of deficiency to each petitioner, in which he used the rates…

1Opinion of the Court

Irwin, Judge•

Respondent determined deficiencies in petitioners’ Federal income tax and additions to tax as follows:

Additions to tax

Docket No. Petitioner Year Deficiency Sec. 6651(a) Sec. 6653(a)

15111-80 Joan D. Thompson 1976 $546.58 $27.33

1977 280.00 $70.00 14.00

1978 470.00 117.50 23.50

15112-80 Gene E. Thompson 1976 617.66 6.29 30.88

1977 968.89 242.22 48.44

1978 1,344.66 336.17 67.23

The issues for decision are: (1) Whether petitioners are entitled to compute their Federal income taxes pursuant to the joint return tax rates set forth in section 1(a)1 for 1976, 1977, and 1978, and (2) whether…

2Cases cited18 opinions

  1. Cupp v. CommissionerUnited States Tax Court · 1975
  2. Reiff v. CommissionerUnited States Tax Court · 1981
  3. United States v. JohnsonCourt of Appeals for the Fifth Circuit · 1978
  4. United States v. David N. MooreCourt of Appeals for the Seventh Circuit · 1980
  5. Durovic v. CommissionerUnited States Tax Court · 1970

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

3Cited by99 opinions

  1. Jarvis v. CommissionerUnited States Tax Court · 1982
  2. Sloan v. CommissionerUnited States Tax Court · 1994
  3. Phillips v. CommissionerUnited States Tax Court · 1986
  4. Philip S. Morgan v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1986
  5. Patronik-Holder v. CommissionerUnited States Tax Court · 1993

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

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