Rader v. Commissioner
United States Tax Court
Ps failed to file returns for 2003-06 and 2008 (years in issue). The IRS examining agent, using the bank deposits method and information returns issued in connection with payments to P-H or to both Ps, reconstructed Ps' income for the years in issue and determined tax deficiencies and additions to tax under I.R.C. secs. 6651(a)(1) and (2) and 6654, which he incorporated on substitutes for returns (SFRs) for each P for 2003-06 and an SFR for P-H for 2008. The SFRs constituted…
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Ps failed to file returns for 2003-06 and 2008 (years in issue). The IRS examining agent, using the bank deposits method and information returns issued in connection with payments to P-H or to both Ps, reconstructed Ps' income for the years in issue and determined tax deficiencies and additions to tax under I.R.C. secs. 6651(a)(1) and (2) and 6654, which he incorporated on substitutes for returns (SFRs) for each P for 2003-06 and an SFR for P-H for 2008. The SFRs constituted the basis for the notices of deficiency issued to Ps. R filed amendments to answer in docket Nos. 11409-11 and 11476-11…
1Opinion of the Court
Halpern, Judge:
These consolidated cases involve the following determinations of deficiencies in and additions to petitioners’ 2003-06 and petitioner Steven R. Rader’s 2008 Federal income tax: 2
Additions to tax
Year Deficiency Sec. 6651(a)(1) Sec. 6651(a)(2) Sec. 6654(a)
2003 $139,964 $29,804
2004 136,414 30,693 $3,909
2005 144,511 32,515 5,797
2006 212,648 47,846 10,063
2008 7,859 1,768 $1,061 253
Respondent issued identical notices of deficiency (notices) for 2003-06 to each petitioner on February 11, 2011, on the grounds that he was unable “to determine which of the petitioners received the income…
2Cases cited18 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- HIGBEE v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001
- Commissioner v. LundySupreme Court of the United States · 1996
- Glenn Crain v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1984
- United States v. Robert NeffCourt of Appeals for the Ninth Circuit · 1980
13 more not listed; retrieve them via the Exa API.
3Cited by19 opinions
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- John E. Rogers & Frances L. Rogers v. CommissionerUnited States Tax Court · 2018
- Batsch v. Comm'rUnited States Tax Court · 2016
- Benton Williams, Jr. v. CommissionerUnited States Tax Court · 2018
- Dynamo Holdings Limited Partnership, Dynamo, GP, Inc., Tax Matters Partner v. CommissionerUnited States Tax Court · 2018
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