White v. Commissioner
United States Tax Court
Petitioner, as a tax protestor, filed Forms 1040 for the respective taxable years of 1972 and 1973 which disclosed only the names, address, and social security numbers of herself and her husband. They had paid an estimated tax for taxable year 1972 which petitioner seeks to recover as an overpayment.
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Petitioner, as a tax protestor, filed Forms 1040 for the respective taxable years of 1972 and 1973 which disclosed only the names, address, and social security numbers of herself and her husband. They had paid an estimated tax for taxable year 1972 which petitioner seeks to recover as an overpayment. Held, the documents filed by petitioner were not returns and though she is entitled to a credit of the estimated tax against the deficiency for the taxable year 1972, she is barred from recovering any excess of the estimated tax paid as a refund or credit under secs. 6511 and 6512(b)(2)(B),…
1Opinion of the Court
Forrester, Judge:
Respondent has determined deficiencies in petitioner’s Federal income tax for the taxable years 1972 and 1973 in the amounts of $106 and $79, respectively. The issues for our decision are:(1) Whether petitioner’s receipt of Federal Reserve notes constituted taxable income to her;(2) Whether substantially blank, unsigned returns filed by petitioner and her husband were valid joint returns for purposes of section 6011(a);1(3) Whether an overpayment may be credited or refunded under section 6512(b) where petitioner failed to file a return and paid the tax more than 2 years prior…
2Cases cited24 opinions
- Flint v. Stone Tracy Co.Supreme Court of the United States · 1911
- Gajewski v. CommissionerUnited States Tax Court · 1976
- United States v. SullivanSupreme Court of the United States · 1927
- Cupp v. CommissionerUnited States Tax Court · 1975
- Wilkinson v. CommissionerUnited States Tax Court · 1979
19 more not listed; retrieve them via the Exa API.
3Cited by80 opinions
- Commissioner v. LundySupreme Court of the United States · 1996
- Jarvis v. CommissionerUnited States Tax Court · 1982
- Reiff v. CommissionerUnited States Tax Court · 1981
- Pierson v. CommissionerUnited States Tax Court · 2000
- Thompson v. CommissionerUnited States Tax Court · 1982
75 more not listed; retrieve them via the Exa API.