Frazier v. Commissioner
United States Tax Court
P attempted to file a petition, but did not submit a filing fee. The petition was designated as "imperfect," and P was ordered to pay the filing fee or provide information reflecting his financial inability to pay the fee. P then attempted to file an amended petition without submitting a filing fee on the ground that it interfered with his constitutional right or privilege to litigate a constitutional issue involving illegally seized evidence and the suppression of same.
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P attempted to file a petition, but did not submit a filing fee. The petition was designated as "imperfect," and P was ordered to pay the filing fee or provide information reflecting his financial inability to pay the fee. P then attempted to file an amended petition without submitting a filing fee on the ground that it interfered with his constitutional right or privilege to litigate a constitutional issue involving illegally seized evidence and the suppression of same. P was then ordered to either pay the filing fee or be sanctioned by a "dismissal" with respect to all issues upon which P…
1Opinion of the Court
OPINION
GERBER, Judge:
Respondent, by means of a March 6, 1984, notice of deficiency, determined deficiencies in petitioner’s 1966 through 1969 taxable years, as follows:
Additions to tax
Year Deficiency Sec. 6653(b)1 Sec. 6654
1966 $878.63 $439.32 $24.54
1967 1,592.89 796.45 50.89
1968 40,728.94 20,364.47 1,300.20
1969 32,912.06 16,456.03 1,050.65
We have under consideration respondent’s motion for summary judgment, filed March 30, 1987, and respondent’s motion to dismiss for failure to properly prosecute, filed April 4, 1988. The parties have filed various documents2 stating their positions and…
2Cases cited29 opinions
- United States v. LeonSupreme Court of the United States · 1984
- Welch v. HelveringSupreme Court of the United States · 1933
- Boddie v. ConnecticutSupreme Court of the United States · 1971
- United States v. JanisSupreme Court of the United States · 1976
- Stone v. CommissionerUnited States Tax Court · 1971
24 more not listed; retrieve them via the Exa API.
3Cited by15 opinions
- Capitol Fed. Sav. & Loan Ass'n v. CommissionerUnited States Tax Court · 1991
- Houser v. CommissionerUnited States Tax Court · 1991
- Tavery v. United StatesDistrict Court, D. Colorado · 1988
- Estate of Bommer v. CommissionerUnited States Tax Court · 1995
- Guillo v. CommissionerUnited States Tax Court · 1998
10 more not listed; retrieve them via the Exa API.