Edelman v. Commissioner
United States Tax Court
Subsequent to filing petitions in this Court, P was convicted of tax fraud. Prior to a hearing in this Court on the merits of his case, P escaped from prison. P presently remains a fugitive from justice. R filed motions to dismiss based upon P's fugitive status.
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Subsequent to filing petitions in this Court, P was convicted of tax fraud. Prior to a hearing in this Court on the merits of his case, P escaped from prison. P presently remains a fugitive from justice. R filed motions to dismiss based upon P's fugitive status. Held: Inasmuch as there is a connection between the proceedings in this Court and P's criminal conviction for tax fraud, a rational basis exists for disentitling P from utilizing this Court's resources to redetermine his deficiencies and additions to tax while he remains a fugitive from justice. See Ortega-Rodriguez v. United States,…
1Opinion of the Court
OPINION
Jacobs, Judge:
This matter is before the Court on respondent’s motions to dismiss these cases based upon petitioner’s fugitive status.
By separate notices of deficiency, respondent determined the following deficiencies in, and additions to, petitioner’s Federal income taxes:
Docket No. Year Deficiency Addition to tax sec. 6653(a)1 Increased interest sec. 6621(c)
$2,604,677 $130,234 8253-87 CO <3 CO2
1,887,477 94,374 8253-87 CO CO O
Addition to Docket No. Year Deficiency Increased interest sec. 6621(c)
887-88 1981 4,789,095 239,455 2
Unless otherwise indicated, all section references are to the…
2Cases cited15 opinions
- Molinaro v. New JerseySupreme Court of the United States · 1970
- Ortega-Rodriguez v. United StatesSupreme Court of the United States · 1993
- Estelle v. DorroughSupreme Court of the United States · 1975
- Smith v. United StatesSupreme Court of the United States · 1876
- Sally Conforte v. Commissioner of Internal Revenue, Joseph Conforte v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1982
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3Cited by5 opinions
- Johnny Daccarett-Ghia, Alleged Alter Ego or Nominee of Friko Corporation v. Commissioner of Internal Revenue ServiceCourt of Appeals for the D.C. Circuit · 1996
- Mohamed v. Comm'rUnited States Tax Court · 2013
- Edelman v. CommissionerUnited States Tax Court · 1994
- Pecoraro v. CommissionerUnited States Tax Court · 1995
- United States v. EdelmanDistrict Court, D. New Mexico · 2009