Fine v. Commissioner
United States Tax Court
In 1971, petitioner's husband, Maynard, was assessed with a 100-percent penalty for failure to collect and pay over certain employment taxes, and the assessment was not paid.
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In 1971, petitioner's husband, Maynard, was assessed with a 100-percent penalty for failure to collect and pay over certain employment taxes, and the assessment was not paid. Petitioner and Maynard filed joint income tax returns for 1969 and 1972. On Apr. 16, 1973, petitioner and Maynard filed an application for tentative refund from carryback of net operating loss, claiming an overpayment for 1969 as a result of an alleged net operating loss in 1972. The application was tentatively allowed and the resulting overpayment for 1969 was credited against Maynard's unpaid penalty assessment.…
1Opinion of the Court
Betsy Fine, Petitioner v. Commissioner of Internal Revenue, Respondent
Fine v. Commissioner
Docket No. 2493-76
United States Tax Court
70 T.C. 684; 1978 U.S. Tax Ct. LEXIS 76;
August 16, 1978, Filed
Decision will be entered for the respondent.
In 1971, petitioner's husband, Maynard, was assessed with a 100-percent penalty for failure to collect and pay over certain employment taxes, and the assessment was not paid. Petitioner and Maynard filed joint income tax returns for 1969 and 1972. On Apr. 16, 1973, petitioner and Maynard filed an application for tentative refund from carryback of net operating…
2Cases cited11 opinions
- Dolan v. CommissionerUnited States Tax Court · 1965
- Polachek v. CommissionerUnited States Tax Court · 1954
- Coerver v. CommissionerUnited States Tax Court · 1961
- Neri v. CommissionerUnited States Tax Court · 1970
- Rosen v. United StatesDistrict Court, E.D. Pennsylvania · 1975
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