Hatfield v. Commissioner
United States Tax Court
P filed a Form 1040 for 1974 which did not disclose her gross income or give any information with regard to her tax liability for such year. Held: (1) Federal Reserve notes are not accounts receivable and are to be reported as income in accordance with a taxpayer's method of accounting; and (2) the document filed by P was not a "return," and the Commissioner properly imposed the additions to the tax provided in secs. 6651(a) and 6653(a), I.R.C. 1954.
1Opinion of the Court
Simpson, Judge:
The Commissioner determined the following deficiency in, and additions to, the petitioner’s 1974 Federal income tax:
Additions to the tax
Deficiency Sec. 6651(a)1 Sec. 6653(a) Sec. 6654
$884 $221 $44.20 $28.29
The only issues to be decided are whether the petitioner was obligated to file a Federal income tax return for 1974, and if so, whether the document submitted by her constituted a return for such year.
FINDINGS OF FACT
Some of the facts have been stipulated, and those facts are so found.
At the time the petitioner, Lou M. Hatfield, filed the petition herein, she was a resident…
2Cases cited25 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Marchetti v. United StatesSupreme Court of the United States · 1968
- Bixby v. CommissionerUnited States Tax Court · 1972
- Gajewski v. CommissionerUnited States Tax Court · 1976
- United States v. SullivanSupreme Court of the United States · 1927
20 more not listed; retrieve them via the Exa API.
3Cited by227 opinions
- Beard v. Comm'rUnited States Tax Court · 1984
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