Guarino v. Commissioner
United States Tax Court
Rules 1, 61, and 141, Tax Court Rules of Practice and Procedure. -- The deficiencies in income tax determined against petitioners arose from the same transaction which respondent is investigating to ascertain whether deficiencies should be determined against a corporation.
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Rules 1, 61, and 141, Tax Court Rules of Practice and Procedure. -- The deficiencies in income tax determined against petitioners arose from the same transaction which respondent is investigating to ascertain whether deficiencies should be determined against a corporation. At the time the transaction occurred, one of petitioners was the majority stockholder of the corporation but had sold his stock prior to the time respondent commenced the investigation of his tax liability. No notice of deficiency has been issued to the corporation. Held: Rule 61 provides for permissive joinder of parties,…
1Opinion of the Court
OPINION
Scott, Judge:
On June 21, 1976, petitioners filed a Motion for Joinder of Parties in which they sought to have American Offset Printing Co., Inc., joined as a party in this case. Oral argument on this motion was held at Bridgeport, Conn., on October 18, 1976.
The petition filed in this case assigned error to respondent’s determination of deficiencies and additions to tax under section 6653(b), I.R.C. 1954,1 for the calendar years 1968,1969, 1970, and 1971. Most of the adjustments to petitioners’ income set forth in the notice of deficiency resulted from dividend income and long-term…
2Cases cited1 opinion
- Moffat v. CommissionerUnited States Tax Court · 1966
3Cited by13 opinions
- Sampson v. CommissionerUnited States Tax Court · 1983
- Estate of Siegel v. CommissionerUnited States Tax Court · 1977
- Matut v. CommissionerUnited States Tax Court · 1985
- Smith v. CommissionerUnited States Tax Court · 1981
- Estate of Siegel v. CommissionerUnited States Tax Court · 1977
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