Legal Opinion

Patrick Combs v. Commissioner

United States Tax Court

Decided August 5, 2019No. 22748-14Unpublished

1Opinion of the Court

T.C. Memo. 2019-96

UNITED STATES TAX COURT PATRICK COMBS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 22748-14. Filed August 5, 2019. Patrick Combs, pro se. Emerald G. Smith and Min Young Chan, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION THORNTON, Judge: Respondent determined deficiencies in petitioner’s Federal income tax, section 6662(a) accuracy-related penalties, and a section 6651(a)(1) addition to tax as follows:1 1 All section references are to the Internal Revenue Code (Code) in effect at all relevant times, and all Rule references are to the Tax…

2Cases cited23 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. HIGBEE v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001
  3. United States v. BoyleSupreme Court of the United States · 1985
  4. Helvering v. HorstSupreme Court of the United States · 1940
  5. Johnny Weimerskirch v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1979

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