Klein v. Commissioner
United States Tax Court
Held, that if petitioner expects to contest the correctness of a deficiency where an addition to tax under section 6653(b) (fraud penalty) has been determined by respondent, petitioner must allege, under Rule 7(c)(4)(B)5 of the Court's Rules of Practice, facts in his petition upon which he relies as sustaining such an assignment of error.
1Opinion of the Court
OPINION
Dawson, Judge:
On April 14, 1965, respondent sent petitioner a notice determining the following deficiencies and additions to tax:
Additions to tax, Taxable year ' Deficiency scc.ee5S(b)
1958_._ $16, 442. 93 $8, 221. 47
1961_____ 26, 056. 53 13, 028. 27
The determined deficiencies for 1958 and 1961 are based principally on an “expenditures method” computation resulting in certain amounts of alleged unreported income. The notice of deficiencies for both years contains specific explanations of the adjustments with Exhibits A and B attached.
On July 13, 1965, the petitioner filed his petition…
2Cases cited8 opinions
- John Factor v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1960
- Goldsmith v. CommissionerUnited States Tax Court · 1958
- Weinstein v. CommissionerUnited States Tax Court · 1957
- Willits v. CommissionerUnited States Board of Tax Appeals · 1937
- Commissioner of Internal Revenue v. Peter LicavoliCourt of Appeals for the Sixth Circuit · 1958
3 more not listed; retrieve them via the Exa API.
3Cited by41 opinions
- Lavern Scherping v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1984
- Voelker v. CommissionerUnited States Tax Court · 1981
- Pebley v. CommissionerUnited States Tax Court · 1981
- Davenport v. CommissionerUnited States Tax Court · 1989
- Jarvis v. CommissionerUnited States Tax Court · 1980
36 more not listed; retrieve them via the Exa API.