Phillips v. Commissioner
United States Tax Court
P, a U.S. citizen resident abroad, filed untimely Federal income tax returns for 1979, 1980, and 1981 claiming joint return status with his nonresident alien wife. On his 1979 return, P and his wife attached a statement signifying their election to have P's wife treated as a U.S. resident. P's returns stated P's and P's wife's correct address and were signed by P and his wife.
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P, a U.S. citizen resident abroad, filed untimely Federal income tax returns for 1979, 1980, and 1981 claiming joint return status with his nonresident alien wife. On his 1979 return, P and his wife attached a statement signifying their election to have P's wife treated as a U.S. resident. P's returns stated P's and P's wife's correct address and were signed by P and his wife. P's returns were filed after the Commissioner had processed dummy returns that showed P's name, address, and social security number and were otherwise blank, and after the Commissioner, using "married filing separately"…
1Opinion of the Court
Kenneth L. Phillips, Petitioner v. Commissioner of Internal Revenue, Respondent
Phillips v. Commissioner
Docket No. 29091-83
United States Tax Court
86 T.C. 433; 1986 U.S. Tax Ct. LEXIS 138; 86 T.C. No. 27;
March 24, 1986, Filed
Decision will be entered for the petitioner.
P, a U.S. citizen resident abroad, filed untimely Federal income tax returns for 1979, 1980, and 1981 claiming joint return status with his nonresident alien wife. On his 1979 return, P and his wife attached a statement signifying their election to have P's wife treated as a U.S. resident. P's returns stated P's and P's wife's…
Also in this document: Concurrence · Simpson; Concurrence · Parr.
2Cases cited8 opinions
- Durovic v. CommissionerUnited States Tax Court · 1970
- Marko Durovic v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1973
- Thompson v. CommissionerUnited States Tax Court · 1982
- Muriel Heim v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1958
- Heim v. CommissionerUnited States Tax Court · 1956
3 more not listed; retrieve them via the Exa API.