Legal Opinion

Han v. Commissioner

United States Tax Court

Decided August 24, 1993No. Docket No. 9135-90Unpublished

Respondent examined petitioners' 1986, 1987, and 1988 Federal income tax returns and determined tax deficiencies and additions to tax aggregating $ 587,768 (without consideration of additions to tax for fraud under sec. 6653(b)(1)(B)). Respondent issued petitioners a notice of deficiency before issuing petitioners a preliminary notice of deficiency (i.e., a 30-day letter). Approximately 26 months after petitioners filed a petition in this Court for a redetermination of their…

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Respondent examined petitioners' 1986, 1987, and 1988 Federal income tax returns and determined tax deficiencies and additions to tax aggregating $ 587,768 (without consideration of additions to tax for fraud under sec. 6653(b)(1)(B)). Respondent issued petitioners a notice of deficiency before issuing petitioners a preliminary notice of deficiency (i.e., a 30-day letter). Approximately 26 months after petitioners filed a petition in this Court for a redetermination of their Federal income tax liability, respondent's Appeals Office conceded fully the tax deficiencies and additions to tax…

1Opinion of the Court

VINCE S. HAN AND KATHY K. HAN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Han v. Commissioner

Docket No. 9135-90

United States Tax Court

T.C. Memo 1993-386; 1993 Tax Ct. Memo LEXIS 391; 66 T.C.M. (CCH) 499;

August 24, 1993, Filed

Respondent examined petitioners' 1986, 1987, and 1988 Federal income tax returns and determined tax deficiencies and additions to tax aggregating $ 587,768 (without consideration of additions to tax for fraud under sec. 6653(b)(1)(B)). Respondent issued petitioners a notice of deficiency before issuing petitioners a preliminary notice of deficiency (i.e.,…

2Cases cited39 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Pierce v. UnderwoodSupreme Court of the United States · 1988
  3. Commissioner, Immigration & Naturalization Service v. JeanSupreme Court of the United States · 1990
  4. Wichita Term. El. Co. v. Commissioner of Int. R.Court of Appeals for the Tenth Circuit · 1947
  5. Chris D. Stoltzfus and Irma H. Stoltzfus v. United StatesCourt of Appeals for the Third Circuit · 1968

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