Legal Opinion

Bowring v. Commissioner

United States Tax Court

Decided April 1, 1993No. Docket No. 12425-91Unpublished

Held, Respondent's determinations of income tax deficiencies and additions to tax do not constitute estimated income tax within the meaning of I.R.C. sec. 6201(b)(1), which prohibits the assessment of estimated tax.

1Opinion of the Court

HENRY K. BOWRING, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Bowring v. Commissioner

Docket No. 12425-91

United States Tax Court

T.C. Memo 1993-132; 1993 Tax Ct. Memo LEXIS 151; 65 T.C.M. (CCH) 2272;

April 1, 1993, Filed

Decision will be entered for respondent.

Held, Respondent's determinations of income tax deficiencies and additions to tax do not constitute estimated income tax within the meaning of I.R.C. sec. 6201(b)(1), which prohibits the assessment of estimated tax.

Henry K. Bowring, pro se.

For respondent: Patrick W. Lucas.

NIMS

NIMS

MEMORANDUM OPINION

NIMS, Judge: By statutory…

2Cases cited8 opinions

  1. Richards v. United StatesSupreme Court of the United States · 1962
  2. Casey v. CommissionerUnited States Tax Court · 1962
  3. Farber v. CommissionerUnited States Tax Court · 1965
  4. Florence M. Barnes, and Barnes Theatre Ticket Service, Inc., an Illinois Corporation v. The Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1969
  5. United States v. Herbert D. Hover, Doing Business as Ciro'sCourt of Appeals for the Ninth Circuit · 1959

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