Colestock v. Commissioner
United States Tax Court
R determined a deficiency in Ps' Federal income tax for 1984 relying on sec. 6501(e)(1)(A), I.R.C., which provides for a 6-year period of limitations where the taxpayer omits from gross income an amount properly includable therein that is in excess of 25 percent of the amount of gross income stated in the return.
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R determined a deficiency in Ps' Federal income tax for 1984 relying on sec. 6501(e)(1)(A), I.R.C., which provides for a 6-year period of limitations where the taxpayer omits from gross income an amount properly includable therein that is in excess of 25 percent of the amount of gross income stated in the return. R subsequently was granted leave to file an amendment to answer out of time to assert an increased deficiency and additions to tax attributable to the disallowance of a depreciation deduction claimed on Ps' 1984 return. Ps filed a motion for partial summary judgment that the…
1Opinion of the Court
OPINION
Dawson, Judge:
This case was assigned to Chief Special Trial Judge Peter J. Panuthos pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.1 The Court agrees with and adopts the opinion of the Chief Special Trial Judge, which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
Panuthos, Chief Special Trial Judge:
This matter is before the Court on a motion for partial summary judgment filed by Stephen G. Colestock and Susan F. Colestock (petitioners). Petitioners seek partial summary judgment that an increased deficiency and related additions to tax asserted by…
2Cases cited19 opinions
- United States v. American Trucking AssociationsSupreme Court of the United States · 1940
- Naftel v. CommissionerUnited States Tax Court · 1985
- Badaracco v. CommissionerSupreme Court of the United States · 1984
- Zaentz v. CommissionerUnited States Tax Court · 1988
- Reis v. CommissionerUnited States Tax Court · 1942
14 more not listed; retrieve them via the Exa API.
3Cited by30 opinions
- Rhone-Poulenc Surfactants & Specialties, L.P. v. CommissionerUnited States Tax Court · 2000
- Ginsburg v. Comm'rUnited States Tax Court · 2006
- Sadler v. CommissionerUnited States Tax Court · 1999
- Fazi v. CommissionerUnited States Tax Court · 1995
- Harlan v. Comm'rUnited States Tax Court · 2001
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