BUTLER v. COMMISSIONER OF INTERNAL REVENUE
United States Tax Court
P and H filed a joint 1992 Federal income tax return on which H failed to report income from an S corporation in which he was a shareholder. R issued a notice of deficiency jointly to P and H who in response filed a joint petition in this Court. H conceded that his share of the income from the S corporation was improperly omitted from the return. In the petition, P alleged that she was entitled to innocent spouse relief pursuant to sec. 6013(e), I.R.C.
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P and H filed a joint 1992 Federal income tax return on which H failed to report income from an S corporation in which he was a shareholder. R issued a notice of deficiency jointly to P and H who in response filed a joint petition in this Court. H conceded that his share of the income from the S corporation was improperly omitted from the return. In the petition, P alleged that she was entitled to innocent spouse relief pursuant to sec. 6013(e), I.R.C. After trial, Congress enacted sec. 6015, I.R.C., and simultaneously repealed sec. 6013(e), I.R.C. The parties agreed to treat P's claim…
1Opinion of the Court
MICHAEL B. BUTLER AND JEAN BUTLER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
BUTLER v. COMMISSIONER OF INTERNAL REVENUE
No. 27554-96
United States Tax Court
114 T.C. 276; 2000 U.S. Tax Ct. LEXIS 25; 114 T.C. No. 19;
April 28, 2000, Filed
An appropriate order will be issued and decision will be entered for respondent.
P and H filed a joint 1992 Federal income tax return on
which H failed to report income from an S corporation in which
he was a shareholder. R issued a notice of deficiency jointly to
P and H who in response filed a joint petition in this Court. H
conceded that his share…
2Cases cited20 opinions
- Citizens to Preserve Overton Park, Inc. v. VolpeSupreme Court of the United States · 1971
- Zenith Radio Corp. v. Hazeltine Research, Inc.Supreme Court of the United States · 1971
- Naftel v. CommissionerUnited States Tax Court · 1985
- Woodral v. CommissionerUnited States Tax Court · 1999
- BUTLER v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2000
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