Legal Opinion

Cutler v. Commissioner

United States Tax Court

Decided February 28, 1994No. Docket No. 28701-84Unpublished

1Opinion of the Court

CARROLL CUTLER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Cutler v. Commissioner

Docket No. 28701-84

United States Tax Court

T.C. Memo 1994-90; 1994 Tax Ct. Memo LEXIS 91; 67 T.C.M. (CCH) 2295;

February 28, 1994, Filed

For petitioner: Thomas E. Redding and Charles B. Koerth.

For respondent: Lillian D. Brigman.

FAY

FAY

MEMORANDUM FINDINGS OF FACT AND OPINION

FAY, Judge: Respondent determined deficiencies in Federal income tax and additions to tax under section 6651(a)(1) 1 for petitioner and his then spouse 2 as follows:

Addition to tax

Year

Deficiency

Sec. 6651(a)(1)

1979

$ 21,907.09

$ 5,476.77

2Cases cited14 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Wichita Term. El. Co. v. Commissioner of Int. R.Court of Appeals for the Tenth Circuit · 1947
  3. Boehm v. CommissionerSupreme Court of the United States · 1945
  4. United States v. GeneresSupreme Court of the United States · 1972
  5. Joseph R. Dileo, Mary A. Dileo, Walter E. Mycek, Jr., Michele A. Mycek and Arcelo Reproduction Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1992

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