Legal Opinion

Kevin E. Rushing v. Commissioner

United States Tax Court

Decided February 28, 2018No. 25029-15Unpublished

1Opinion of the Court

T.C. Memo. 2018-23

UNITED STATES TAX COURT KEVIN E. RUSHING, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 25029-15. Filed February 28, 2018. P did not file income tax returns for the 2010, 2011, and 2012 taxable years. R prepared substitutes for returns, determining that P had unreported income during those years, and issued a notice of deficiency making certain determinations as to P’s income. Held: R’s determinations are sustained because P has failed to prove by a preponderance of the evidence that the determinations in the notice of deficiency are incorrect. James…

2Cases cited23 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. United States v. JanisSupreme Court of the United States · 1976
  3. Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
  4. Wichita Term. El. Co. v. Commissioner of Int. R.Court of Appeals for the Tenth Circuit · 1947
  5. Tokarski v. CommissionerUnited States Tax Court · 1986

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