Bernal v. Comm'r
United States Tax Court
P filed individual Federal income tax returns as married, filing separate, for the taxable years 1993, 1994, 1995, and 1996. During these years, P was married and was domiciled in California, a community property State. R issued notices of deficiency for the years involved, and a timely petition was not filed. P later made a request for relief from tax on community property income pursuant to sec. 66(c), I.R.C.
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P filed individual Federal income tax returns as married, filing separate, for the taxable years 1993, 1994, 1995, and 1996. During these years, P was married and was domiciled in California, a community property State. R issued notices of deficiency for the years involved, and a timely petition was not filed. P later made a request for relief from tax on community property income pursuant to sec. 66(c), I.R.C. R issued a notice of determination denying the request for relief. P filed a petition seeking review of R's determination. R moved to dismiss for lack of jurisdiction. Held: Unlike…
1Opinion of the Court
KATHRYN BERNAL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Bernal v. Comm'r
No. 930-02
United States Tax Court
120 T.C. 102; 2003 U.S. Tax Ct. LEXIS 7; 120 T.C. No. 6; RIA TM 55042;
February 20, 2003, Filed
An order was issued granting respondent's motion to dismiss for lack of jurisdiction and to strike as to taxable years 1993, 1994, 1995, and 1996.
P filed individual Federal income tax returns as married,
filing separate, for the taxable years 1993, 1994, 1995, and
1996. During these years, P was married and was domiciled in
California, a community property State. R issued notices of
d…
2Cases cited12 opinions
- Naftel v. CommissionerUnited States Tax Court · 1985
- United States v. MitchellSupreme Court of the United States · 1971
- United States v. RyersonSupreme Court of the United States · 1941
- Fernandez v. CommissionerUnited States Tax Court · 2000
- Cathy Miller Hardy v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1999
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