Wheeler v. Comm'r
United States Tax Court
P failed to file his Federal income tax return for 2003. R issued a notice of deficiency in which he determined that P was liable for an income tax deficiency and for additions to tax under secs. 6651 and 6654, I.R.C.
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P failed to file his Federal income tax return for 2003. R issued a notice of deficiency in which he determined that P was liable for an income tax deficiency and for additions to tax under secs. 6651 and 6654, I.R.C. At trial, R, who had the burden of production under sec. 7491(c), I.R.C., with respect to the additions to tax, produced evidence that P did not file a Federal income tax return for 2003 and that P did not make any estimated tax payments for 2003, but R did not introduce any evidence regarding P's 2002 taxable year. Specifically, R failed to introduce evidence as to whether P…
1Opinion of the Court
OPINION
Marvel, Judge:
Respondent determined a deficiency in petitioner’s 2003 Federal income tax of $9,507 and additions to tax under section 6651(a)(1)1 of $2,037, under section 6651(a)(2) of $498, and under section 6654 of $245. Petitioner petitioned for a redetermination of the deficiency and the additions to tax. After concessions,2 the issues for decision are:(1) Whether respondent issued a valid notice of deficiency for petitioner’s 2003 taxable year;(2) whether petitioner is liable for an addition to tax under section 6651(a)(1) for failing to file his 2003 Federal income tax return;(3)…
2Cases cited12 opinions
- HIGBEE v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001
- United States v. BoyleSupreme Court of the United States · 1985
- Glenn Crain v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1984
- Norman E. Coleman v. Commissioner of Internal Revenue, Gary Holder v. Secretary of the Treasury and United States of AmericaCourt of Appeals for the Seventh Circuit · 1986
- Jarvis v. CommissionerUnited States Tax Court · 1982
7 more not listed; retrieve them via the Exa API.
3Cited by143 opinions
- Rodriguez v. Comm'rUnited States Tax Court · 2009
- El v. CommissionerUnited States Tax Court · 2015
- Cadwell v. CommissionerUnited States Tax Court · 2011
- Ulloa v. Comm'rUnited States Tax Court · 2010
- Adler v. Comm'rUnited States Tax Court · 2010
138 more not listed; retrieve them via the Exa API.