Legal Opinion

Doggett v. Commissioner

United States Tax Court

Decided April 15, 1976No. Docket Nos. 9106-72, 9074-75Published

Rule 121, Tax Court Rules of Practice and Procedure. -- In 1972, the Commissioner issued a notice of deficiency determining that the petitioners realized taxable gain from the sale of stock in 1969. Subsequently, the Commissioner issued another notice of deficiency determining that the petitioners realized such gain in 1972. The Commissioner concedes that the subsequent notice of deficiency is an alternative determination, and not a cumulative one.

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Rule 121, Tax Court Rules of Practice and Procedure. -- In 1972, the Commissioner issued a notice of deficiency determining that the petitioners realized taxable gain from the sale of stock in 1969. Subsequently, the Commissioner issued another notice of deficiency determining that the petitioners realized such gain in 1972. The Commissioner concedes that the subsequent notice of deficiency is an alternative determination, and not a cumulative one. Held, the Commissioner did not, as a matter of law, abandon his original determination when he made a subsequent alternative determination, and…

1Opinion of the Court

I. E. Doggett and Ovater K. Doggett, Petitioners v. Commissioner of Internal Revenue, Respondent

Doggett v. Commissioner

Docket Nos. 9106-72, 9074-75

United States Tax Court

66 T.C. 101; 1976 U.S. Tax Ct. LEXIS 125;

April 15, 1976, Filed

Rule 121, Tax Court Rules of Practice and Procedure. -- In 1972, the Commissioner issued a notice of deficiency determining that the petitioners realized taxable gain from the sale of stock in 1969. Subsequently, the Commissioner issued another notice of deficiency determining that the petitioners realized such gain in 1972. The Commissioner concedes that the…

2Cases cited18 opinions

  1. Commissioner v. SunnenSupreme Court of the United States · 1948
  2. Shiosaki v. CommissionerUnited States Tax Court · 1974
  3. Nat Harrison Assoc., Inc. v. CommissionerUnited States Tax Court · 1964
  4. Papineau v. CommissionerUnited States Tax Court · 1957
  5. Hoeme v. CommissionerUnited States Tax Court · 1974

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