Corkrey v. Commissioner
United States Tax Court
R received from the Social Security Administration (SSA) inaccurate information showing that, during 1987, P received certain compensation in the amount of $ 35,100 for teaching a scuba diving course. In fact, P received only $ 351 for such compensation. P did not file a tax return for 1987 or 1988. On the basis of the information from the SSA, R issued a notice of deficiency to P, to which notice P did not respond.
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R received from the Social Security Administration (SSA) inaccurate information showing that, during 1987, P received certain compensation in the amount of $ 35,100 for teaching a scuba diving course. In fact, P received only $ 351 for such compensation. P did not file a tax return for 1987 or 1988. On the basis of the information from the SSA, R issued a notice of deficiency to P, to which notice P did not respond. R assessed the tax determined to be due and attached a lien to P's bank account. During 1996, P was unable to obtain a home loan because of the tax lien and outstanding balances…
1Opinion of the Court
Wells, Chief Judge:
The instant case involves petitioners’ claim for administrative costs of $5,377.22 pursuant to section 7430.1 Some of the facts have been stipulated and are so found. Petitioners resided in Nassau, New York, when they filed their petition.
FINDINGS OF FACT
During 1987 and 1988, petitioner Raymond P. Corkrey (petitioner) and his former wife Gunn Corkrey (petitioner’s ex-wife) were estranged. They divorced in 1990. Petitioner failed to file timely Forms 1040 for the years 1987 and 1988. Petitioner’s gross income for each of the years 1987 and 1988 exceeded the filing…
2Cases cited12 opinions
- Pierce v. UnderwoodSupreme Court of the United States · 1988
- Sokol v. CommissionerUnited States Tax Court · 1989
- Wasie v. CommissionerUnited States Tax Court · 1986
- Powers v. CommissionerUnited States Tax Court · 1993
- Estate of Frank Martin Perry, Sr., Deceased, Michael C. Perry, Whit S. Perry, and Robert S. Perry, Co-Executors v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1991
7 more not listed; retrieve them via the Exa API.
3Cited by10 opinions
- Haas & Assocs. Accountancy Corp. v. Comm'rUnited States Tax Court · 2001
- Coburn v. Comm'rUnited States Tax Court · 2006
- Corkrey v. CommissionerUnited States Tax Court · 2000
- Elder v. Comm'rUnited States Tax Court · 2007
- F-Star Prop. Mgmt. v. Comm'rUnited States Tax Court · 2013
5 more not listed; retrieve them via the Exa API.