Cornick v. Commissioner
United States Tax Court
In his pleadings, P alleged that refund checks issued by R and due to P were misappropriated by P's attorney. R's deficiency computation takes into account the refunds issued to P. P argues that the deficiency should be reduced to the extent that refund checks were issued to him but never received by him.
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In his pleadings, P alleged that refund checks issued by R and due to P were misappropriated by P's attorney. R's deficiency computation takes into account the refunds issued to P. P argues that the deficiency should be reduced to the extent that refund checks were issued to him but never received by him. R filed a motion for partial summary judgment on the premise that the Court does not have jurisdiction to consider the question of whether the amount of the deficiency should reflect refunds issued by R and not received by P. Held, it is within the Court's jurisdiction to consider the…
1Opinion of the Court
LYNN S. CORNICK, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Cornick v. Commissioner
Docket No. 17425-82.
United States Tax Court
T.C. Memo 1985-513; 1985 Tax Ct. Memo LEXIS 114; 50 T.C.M. (CCH) 1217; T.C.M. (RIA) 85513;
September 30, 1985.
In his pleadings, P alleged that refund checks issued by R and due to P were misappropriated by P's attorney. R's deficiency computation takes into account the refunds issued to P. P argues that the deficiency should be reduced to the extent that refund checks were issued to him but never received by him. R filed a motion for partial summary…
2Cases cited37 opinions
- Jacklin v. CommissionerUnited States Tax Court · 1982
- Espinoza v. CommissionerUnited States Tax Court · 1982
- Commissioner v. Gooch Milling & Elevator Co.Supreme Court of the United States · 1944
- Markwardt v. CommissionerUnited States Tax Court · 1975
- United States Ex Rel. Girard Trust Co. v. HelveringSupreme Court of the United States · 1937
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