Kruszynski v. Commissioner
United States Tax Court
Held, P's motions (1) to vacate, as to P, decisions which have become final on the grounds (a) that the Court lacked jurisdiction as to P since attorney chosen by P's spouse lacked authority to file case on P's behalf, and (b) that fraud on the Court was perpetrated; and (2) to "Reinstate Action" to permit Court to consider P's innocent spouse claim pursuant to I.R.C. sec. 6013(e), are denied.
1Opinion of the Court
JOSEPH A. KRUSZYNSKI AND DALE S. KRUSZYNSKI, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Kruszynski v. Commissioner
Docket Nos. 27075-81, 23629-82, 11567-83, 18658-84
United States Tax Court
T.C. Memo 1993-271; 1993 Tax Ct. Memo LEXIS 271; 65 T.C.M. (CCH) 2982;
June 21, 1993, Filed
Held, P's motions (1) to vacate, as to P, decisions which have become final on the grounds (a) that the Court lacked jurisdiction as to P since attorney chosen by P's spouse lacked authority to file case on P's behalf, and (b) that fraud on the Court was perpetrated; and (2) to "Reinstate Action" to…
2Cases cited7 opinions
- Ben Abatti and Margaret Abatti v. Commissioner of the Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1988
- Josephine C. Toscano AKA Josephine C. Zelasko v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1971
- Peter Billingsley v. Commissioner of the Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1989
- Abatti v. CommissionerUnited States Tax Court · 1986
- Adams v. CommissionerUnited States Tax Court · 1985
2 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Dahl v. CommissionerUnited States Tax Court · 1995