Legal Opinion
Rodriguez v. Comm'r
United States Tax Court
Decided January 29, 2009No. 16342-04UnpublishedCited by 19 opinions
1Opinion of the Court
JOHN M. RODRIGUEZ, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Rodriguez v. Comm'r
No. 16342-04
United States Tax Court
T.C. Memo 2009-22; 2009 Tax Ct. Memo LEXIS 20; 97 T.C.M. (CCH) 1090;
January 29, 2009, Filed
Jerry B. Register, for petitioner.
Randall Durfee, for respondent.
Holmes, Mark V.
MARK V. HOLMES
MEMORANDUM OPINION
HOLMES, Judge: John Rodriguez is a real-estate sales manager who also had personal real-estate investments. He did not file income tax returns from 1998 through 2001. The IRS noticed, and created "substitutes for returns" (SFRs) for him, calculating his tax…
2Cases cited22 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- HIGBEE v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001
- United States v. GilmoreSupreme Court of the United States · 1963
17 more not listed; retrieve them via the Exa API.
3Cited by19 opinions
- Feinberg v. Comm'rUnited States Tax Court · 2017
- Kazhukauskas v. Comm'rUnited States Tax Court · 2012
- Alternative Health Care Advocates v. CommissionerUnited States Tax Court · 2018
- Alubunkudi v. Comm'rUnited States Tax Court · 2014
- Amanda Reynolds, individually, and Amanda Reynolds on behalf of Finnegan Mary Reynolds v. United States of America (Internal Revenue Service)District Court, E.D. New York · 2025
14 more not listed; retrieve them via the Exa API.