Legal Opinion

Bourekis v. Comm'r

United States Tax Court

Decided January 13, 1998No. Tax Ct. Dkt. No. 5894-97Published

R determined a deficiency for the taxable year 1981. The notice of deficiency did not include any additions to tax or penalties; however, the notice did include a statement that interest would accrue on the deficiency. In a timely petition, Ps attempt to place in dispute penalties and interest.

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R determined a deficiency for the taxable year 1981. The notice of deficiency did not include any additions to tax or penalties; however, the notice did include a statement that interest would accrue on the deficiency. In a timely petition, Ps attempt to place in dispute penalties and interest. Ps did not make a written request with the IRS to abate interest; however, they assert that they made an informal request and that the notice of deficiency should be considered a "final determination" not to abate interest under sec. 6404(g). R filed a motion to dismiss for lack of jurisdiction and to…

1Opinion of the Court

JAMES G. & KATHERINE BOUREKIS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Bourekis v. Comm'r

Tax Ct. Dkt. No. 5894-97

United States Tax Court

110 T.C. 20; 1998 U.S. Tax Ct. LEXIS 3; 110 T.C. No. 3;

January 13, 1998, Filed

An order will be issued granting respondent's Motion to Dismiss for Lack of Jurisdiction and to Strike With Respect to Penalties and Interest.

R determined a deficiency for the taxable year 1981. The notice of deficiency did not include any additions to tax or penalties; however, the notice did include a statement that interest would accrue on the deficiency. In a…

2Cases cited15 opinions

  1. Naftel v. CommissionerUnited States Tax Court · 1985
  2. Monge v. CommissionerUnited States Tax Court · 1989
  3. United States v. HabigSupreme Court of the United States · 1968
  4. LTV Corp. v. CommissionerUnited States Tax Court · 1975
  5. Normac, Inc. v. CommissionerUnited States Tax Court · 1988

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