Koprowski v. Commissioner
United States Tax Court
P and W filed a joint return for 2006. R issued a notice of deficiency, and P and W filed a petition asking this Court to redetermine that deficiency. They elected to have the case proceed under small tax case procedures pursuant to I.R.C. sec. 7463. P signed the petition and all other filings.
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P and W filed a joint return for 2006. R issued a notice of deficiency, and P and W filed a petition asking this Court to redetermine that deficiency. They elected to have the case proceed under small tax case procedures pursuant to I.R.C. sec. 7463. P signed the petition and all other filings. P and W moved for summary judgment; R cross-moved for summary judgment; and P and W opposed on various grounds, including P's entitlement to innocent spouse relief from joint liability under I.R.C. sec. 6015. At a calendar call before the Court, P spoke for himself and W. The parties withdrew their…
1Opinion of the Court
EUGENE KOPROWSKI, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Koprowski v. Comm'r
Docket No. 13048-10.
United States Tax Court
138 T.C. 54; 2012 U.S. Tax Ct. LEXIS 5; 138 T.C. No. 5;
February 6, 2012, Filed
An appropriate order and decision will be entered.
P and W filed a joint return for 2006. R issued a notice of deficiency, and P and W filed a petition asking this Court to redetermine that deficiency. They elected to have the case proceed under small tax case procedures pursuant to I.R.C. sec. 7463. P signed the petition and all other filings. P and W moved for summary judgment; R…
Also in this document: Concurrence.
2Cases cited24 opinions
- Almendarez-Torres v. United StatesSupreme Court of the United States · 1998
- Allen v. McCurrySupreme Court of the United States · 1980
- Parklane Hosiery Co. v. ShoreSupreme Court of the United States · 1979
- Montana v. United StatesSupreme Court of the United States · 1979
- Taylor v. SturgellSupreme Court of the United States · 2008
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