Legal Opinion

Wheeler v. Comm'r

United States Tax Court

Decided December 6, 2006No. 15720-05Published

P failed to file his Federal income tax return for 2003. R issued a notice of deficiency in which he determined that P was liable for an income tax deficiency and for additions to tax under secs. 6651 and 6654, I.R.C.

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P failed to file his Federal income tax return for 2003. R issued a notice of deficiency in which he determined that P was liable for an income tax deficiency and for additions to tax under secs. 6651 and 6654, I.R.C. At trial, R, who had the burden of production under sec. 7491(c), I.R.C., with respect to the additions to tax, produced evidence that P did not file a Federal income tax return for 2003 and that P did not make any estimated tax payments for 2003, but R did not introduce any evidence regarding P's 2002 taxable year. Specifically, R failed to introduce evidence as to whether P…

1Opinion of the Court

CHARLES RAYMOND WHEELER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Wheeler v. Comm'r

No. 15720-05

United States Tax Court

127 T.C. 200; 2006 U.S. Tax Ct. LEXIS 35; 127 T.C. No. 14;

December 6, 2006, Filed

Wheeler v. Commissioner, T.C. Memo 2006-109, 2006 Tax Ct. Memo LEXIS 110 (T.C., 2006)

P failed to file his Federal income tax return for 2003. R

issued a notice of deficiency in which he determined that P was

liable for an income tax deficiency and for additions to tax

under secs. 6651 and 6654, I.R.C. At trial, R, who had the

burden of production under sec. 7491(c), I.R.C., with…

2Cases cited14 opinions

  1. HIGBEE v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001
  2. United States v. BoyleSupreme Court of the United States · 1985
  3. Glenn Crain v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1984
  4. Norman E. Coleman v. Commissioner of Internal Revenue, Gary Holder v. Secretary of the Treasury and United States of AmericaCourt of Appeals for the Seventh Circuit · 1986
  5. Jarvis v. CommissionerUnited States Tax Court · 1982

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