Mendes v. Comm'r
United States Tax Court
P has been continuously incarcerated since June 17, 1988. For P's 1988 taxable year, R (1) determined a tax deficiency based upon amounts reported on information returns as having been paid to P during that year, (2) imposed the 10-percent additional tax under sec. 72(t)(1), I.R.C., and (3) determined that P was subject to additions to tax under secs. 6651(a)(1), 6653(a)(1), and 6654, I.R.C.
Read the full summary
P has been continuously incarcerated since June 17, 1988. For P's 1988 taxable year, R (1) determined a tax deficiency based upon amounts reported on information returns as having been paid to P during that year, (2) imposed the 10-percent additional tax under sec. 72(t)(1), I.R.C., and (3) determined that P was subject to additions to tax under secs. 6651(a)(1), 6653(a)(1), and 6654, I.R.C. More than 2 years after R issued the notice of deficiency, P filed a 1988 return in which he reported the income from the 1988 information returns and listed deductions and dependency exemptions, which,…
1Opinion of the Court
Halpern, Judge:
By notice of deficiency dated May 3, 1995 (the notice), respondent determined a deficiency in and additions to petitioner’s Federal income tax for calendar year 1988 (sometimes, the audit year) as follows:
Additions to tax
Deficiency Sec. 6651(a)(1) Sec. 6653(a)(1) Sec. 6654
$8,487 $2,122 $424 $484
The adjustments giving rise to the deficiency are respondent’s inclusion in income of amounts reported on information returns as having been paid to petitioner during 1988 (sometimes, the income items), and his imposition of the 10-per-cent additional tax on early distributions from…
2Cases cited27 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- United States v. BoyleSupreme Court of the United States · 1985
- Dreicer v. CommissionerUnited States Tax Court · 1982
- Vanicek v. CommissionerUnited States Tax Court · 1985
- Jasionowski v. CommissionerUnited States Tax Court · 1976
22 more not listed; retrieve them via the Exa API.
3Cited by99 opinions
- Rodriguez v. Comm'rUnited States Tax Court · 2009
- United States v. McFerrinCourt of Appeals for the Fifth Circuit · 2009
- Appleton v. Comm'rUnited States Tax Court · 2013
- Adler v. Comm'rUnited States Tax Court · 2010
- Browning v. Comm'rUnited States Tax Court · 2011
94 more not listed; retrieve them via the Exa API.