Rimple v. Commissioner
United States Tax Court
Held: (1) The statutory notice of deficiency was not issued arbitrarily; (2) petitioner failed to carry her burden of proving any error in respondent's deficiency determination; (3) section 66(c), I.R.C. 1954, as amended, does not relieve petitioner of tax liability on unreported community income and (4) petitioner is liable for additions to tax under sections 6651(a) and 6653(a), I.R.C. 1954.
1Opinion of the Court
LUCY RIMPLE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Rimple v. Commissioner
Docket No. 5125-79.
United States Tax Court
T.C. Memo 1985-245; 1985 Tax Ct. Memo LEXIS 386; 49 T.C.M. (CCH) 1533; T.C.M. (RIA) 85245;
May 23, 1985.
Held: (1) The statutory notice of deficiency was not issued arbitrarily; (2) petitioner failed to carry her burden of proving any error in respondent's deficiency determination; (3) section 66(c), I.R.C. 1954, as amended, does not relieve petitioner of tax liability on unreported community income and (4) petitioner is liable for additions to tax under…
2Cases cited24 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Holland v. United StatesSupreme Court of the United States · 1955
- Greenberg's Express, Inc. v. CommissionerUnited States Tax Court · 1974
- United States v. MitchellSupreme Court of the United States · 1971
- Seymour Silverman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1976
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