Woods v. Commissioner
United States Tax Court
Held, various "tax protester" arguments rejected. Held, further, additions to tax under secs. 6651 and 6653 upheld. Held, further, withholding credits must be subtracted from the "understatement" to arrive at the "amount of any underpayment" in computing the addition to tax under sec. 6661(a). Held, further, sec. 1.6661-2(a), Income Tax Regs. is invalid.
1Opinion of the Court
OPINION
CHABOT, Judge:
This case was assigned to Special Trial Judge Pate pursuant to the provisions of section 7456(d) (redesignated as section 7443A(b) by the Tax Reform Act of 1986, Pub. L. 99-514, 100 Stat. 2755) and Rules 180 and 181.1 The Court agrees with and adopts her opinion which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
PATE, Special Trial Judge:
This case is before the Court
on respondent’s motion for judgment on the pleadings, pursuant to Rule 120(a). Petitioner filed an opposition thereto. Subsequently, this Court issued an order asking respondent to file a supplemental…
2Cases cited25 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Tennessee Valley Authority v. HillSupreme Court of the United States · 1978
- Bixby v. CommissionerUnited States Tax Court · 1972
- Rubin v. United StatesSupreme Court of the United States · 1981
- Brushaber v. Union Pacific RailroadSupreme Court of the United States · 1916
20 more not listed; retrieve them via the Exa API.
3Cited by104 opinions
- Rhone-Poulenc Surfactants & Specialties, L.P. v. CommissionerUnited States Tax Court · 2000
- Martin Ice Cream Co. v. Comm'rUnited States Tax Court · 1998
- Tweeddale v. CommissionerUnited States Tax Court · 1989
- Cluck v. CommissionerUnited States Tax Court · 1995
- Gantner v. CommissionerUnited States Tax Court · 1988
99 more not listed; retrieve them via the Exa API.