Legal Opinion

Dwyer v. Commissioner

United States Tax Court

Decided February 21, 1991No. Docket No. 2793-88Unpublished

1Opinion of the Court

MICHAEL J. DWYER AND LINDA L. DWYER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Dwyer v. Commissioner

Docket No. 2793-88

United States Tax Court

T.C. Memo 1991-65; 1991 Tax Ct. Memo LEXIS 84; 61 T.C.M. (CCH) 1911; T.C.M. (RIA) 91065;

February 21, 1991, Filed

Decision will be entered under Rule 155.

Peter M. Wolverton, for the petitioners.

Bruce W. Kent, for the respondent.

GERBER, Judge.

GERBER

MEMORANDUM FINDINGS OF FACT AND OPINION

Respondent determined a deficiency in and an addition to petitioners' Federal income tax as follows:

Addition to Tax

Year

Deficiency

Section 6651(a)(1) 1

1981

$…

2Cases cited7 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Morgan v. CommissionerUnited States Tax Court · 1966
  3. Malinowski v. CommissionerUnited States Tax Court · 1979
  4. 508 Clinton St. Corp. v. CommissionerUnited States Tax Court · 1987
  5. Pierre Godart and Suzanne Godart v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1970

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