Abeles v. Commissioner
United States Tax Court
W and H filed joint Federal income tax returns for their 1975, 1976, and 1977 taxable years. R issued a joint notice of deficiency with respect to W and H's 1976 taxable year on Oct. 15, 1980. W filed a Federal income tax return in the status of married, filing separately, on June 15, 1982, with respect to her 1981 taxable year.
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W and H filed joint Federal income tax returns for their 1975, 1976, and 1977 taxable years. R issued a joint notice of deficiency with respect to W and H's 1976 taxable year on Oct. 15, 1980. W filed a Federal income tax return in the status of married, filing separately, on June 15, 1982, with respect to her 1981 taxable year. Such return indicated a new address for W. On Nov. 30, 1982, R sent a notice of deficiency to W and H with respect to their 1975 and 1977 taxable years. Although R's computer records contained a different address for W and H, R issued only a single joint notice…
1Opinion of the Court
OPINION
FAY, Judge:
Respondent determined deficiencies in petitioner’s Federal income tax as follows:
Year Deficiency
1975 . $48,591.00
1976 . 31,892.82
1977 . 29,844.00
In two previously docketed cases, Harold A. Abeles and Barbara Abeles v. Commissioner, docket Nos. 1372-81 and 4433-83, pertaining to the Abeles’ 1976, and 1975 and 1977 tax years, respectively, this Court granted respondent’s motions to dismiss for lack of prosecution and entered decisions in respondent’s favor in the reduced amounts of $24,008, $19,790.32, and $23,809, with respect to the Abeles’ 1975, 1976, and 1977 taxable…
2Cases cited28 opinions
- United States v. American Trucking AssociationsSupreme Court of the United States · 1940
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Cool Fuel, Incorporated v. William H. Connett, Etc.Court of Appeals for the Ninth Circuit · 1982
- Takao Ozawa v. United StatesSupreme Court of the United States · 1922
- United States v. Edward M. ZollaCourt of Appeals for the Ninth Circuit · 1984
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- Miller v. CommissionerUnited States Tax Court · 1989
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