Brennan v. Comm'r
United States Tax Court
P failed to file a Federal income tax return for tax year 2008. R prepared a substitute for return ("SFR") pursuant to I.R.C. sec. 6020 and issued to P a notice of deficiency that included the tax shown on the SFR as well as additions to tax under I.R.C. secs. 6651(a)(1) and (2) and 6654. P did not file a petition with this Court for redetermination of the deficiency, and R assessed the tax and the additions.
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P failed to file a Federal income tax return for tax year 2008. R prepared a substitute for return ("SFR") pursuant to I.R.C. sec. 6020 and issued to P a notice of deficiency that included the tax shown on the SFR as well as additions to tax under I.R.C. secs. 6651(a)(1) and (2) and 6654. P did not file a petition with this Court for redetermination of the deficiency, and R assessed the tax and the additions. R later issued to P a final notice of intent to levy to collect the unpaid tax liability. In response P requested a collection due process hearing before R's Office of Appeals…
1Opinion of the Court
JOSEPH M. BRENNAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Brennan v. Comm'r
Docket No. 1248-12L.
United States Tax Court
T.C. Memo 2013-123; 2013 Tax Ct. Memo LEXIS 124; 105 T.C.M. (CCH) 1724;
May 8, 2013, Filed
An appropriate order and decision will be entered.
P failed to file a Federal income tax return for tax year 2008. R prepared a substitute for return ("SFR") pursuant to I.R.C. sec. 6020 and issued to P a notice of deficiency that included the tax shown on the SFR as well as additions to tax under I.R.C. secs. 6651(a)(1) and (2) and 6654. P did not file a petition with…
2Cases cited9 opinions
- Goza v. CommissionerUnited States Tax Court · 2000
- Sego v. CommissionerUnited States Tax Court · 2000
- Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
- Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
- Murphy v. Commissioner of IRSCourt of Appeals for the First Circuit · 2006
4 more not listed; retrieve them via the Exa API.