Adler v. Comm'r
United States Tax Court
From 1989 to 2006 P grew flowers and vegetables for sale in greenhouses on the same property as his personal residence. From 1999 to the present, P's wife sold rubber stamps and related products to stamping hobbyists on commission. P failed to timely file his tax returns for the 2001 through 2004 tax years. In response, the IRS prepared substitutes for returns and issued notices of deficiency to P for each of those years.
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From 1989 to 2006 P grew flowers and vegetables for sale in greenhouses on the same property as his personal residence. From 1999 to the present, P's wife sold rubber stamps and related products to stamping hobbyists on commission. P failed to timely file his tax returns for the 2001 through 2004 tax years. In response, the IRS prepared substitutes for returns and issued notices of deficiency to P for each of those years. In the notices of deficiency, the IRS determined deficiencies and additions to tax under I.R.C. sec. 6651(a)(1) and (2) and sec. 6654. In 2008 P submitted to the IRS what he…
1Opinion of the Court
GARY ALAN ADLER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Adler v. Comm'r
Nos. 28454-07, 28455-07, 28456-07, 28457-07
United States Tax Court
T.C. Memo 2010-47; 2010 Tax Ct. Memo LEXIS 47; 99 T.C.M. (CCH) 1181;
March 16, 2010, Filed
From 1989 to 2006 P grew flowers and vegetables for sale in greenhouses on the same property as his personal residence. From 1999 to the present, P's wife sold rubber stamps and related products to stamping hobbyists on commission. P failed to timely file his tax returns for the 2001 through 2004 tax years. In response, the IRS prepared substitutes for…
2Cases cited19 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- United States v. BoyleSupreme Court of the United States · 1985
14 more not listed; retrieve them via the Exa API.
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- Holden v. Comm'rUnited States Tax Court · 2015
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