Hebrank v. Commissioner
United States Tax Court
Petitioner filed false W-4 forms, deliberately falsified his W-2's, and filed inadequate returns. Held, petitioner is liable for additions to tax under sec. 6653(b), I.R.C. 1954. Raley v. Commissioner, 676 F.2d 980 (3d Cir. 1982), revg. on this issue T.C. Memo. 1980-571, distinguished.
1Opinion of the Court
Wilbur, Judge:
Respondent determined a deficiency of $6,906.70 in the 1979 Federal income tax of petitioner Steve A. Hebrank, and also imposed an addition to tax under section 6653(b)1 of $3,453.35. The sole issue for our decision is whether any part of petitioner’s underpayment in 1979 was due to fraud.2
FINDINGS OF FACT
Petitioner Steve A. Hebrank lived in Riverview, Fla., when the return and the petition in this case were filed.
Petitioner was a pipefitter, and in 1979 earned $28,416.64 from various employers. During 1979, he filed W-4 forms on which hé claimed to be exempt from Federal…
2Cases cited10 opinions
- Helvering v. MitchellSupreme Court of the United States · 1938
- Rowlee v. CommissionerUnited States Tax Court · 1983
- Chris D. Stoltzfus and Irma H. Stoltzfus v. United StatesCourt of Appeals for the Third Circuit · 1968
- Bolen Webb and Cornelia Webb v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1968
- Habersham-Bey v. CommissionerUnited States Tax Court · 1982
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3Cited by213 opinions
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- Castillo v. CommissionerUnited States Tax Court · 1985
- Stringer v. CommissionerUnited States Tax Court · 1985
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