Jarvis v. Commissioner
United States Tax Court
Petitioner submitted a Form 1040 for 1976 to the Internal Revenue Service. Thereon he failed to disclose the required information respecting his income and the tax due thereon.
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Petitioner submitted a Form 1040 for 1976 to the Internal Revenue Service. Thereon he failed to disclose the required information respecting his income and the tax due thereon. A notice of deficiency was issued to petitioner on Mar. 27, 1981, for the taxable years 1976 and 1977. In the petition, the statute of limitations is raised as a plea in bar for the taxable year 1976, and it is alleged that the notice of deficiency is invalid since it fails to cite the statutory law on which the income tax deficiencies are predicated. On Dec. 9, 1981, respondent filed a motion for summary judgment,…
1Opinion of the Court
OPINION
Dawson, Judge:
This case was assigned to Special Trial Judge Francis J. Cantrel for the purpose of considering and ruling on respondent’s motion for summary judgment. After a review of the record, we agree with and adopt his opinion which is set forth below.1
OPINION OF THE SPECIAL TRIAL JUDGE
Cantrel, Special Trial Judge-. This case is presently before the Court on respondent’s motion for summary judgment filed on December 9,1981, pursuant to Rule 121, Tax Court Rules of Practice and Procedure.2
Respondent, in his notice of deficiency issued to petitioner on March 27, 1981, determined…
2Cases cited42 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Sartor v. Arkansas Natural Gas Corp.Supreme Court of the United States · 1944
- Perma Research and Development Company v. The Singer CompanyCourt of Appeals for the Second Circuit · 1969
- Cupp v. CommissionerUnited States Tax Court · 1975
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3Cited by204 opinions
- Foster v. Comm'rUnited States Tax Court · 1983
- Wheeler v. Comm'rUnited States Tax Court · 2006
- Fernandez v. CommissionerUnited States Tax Court · 2000
- Scar v. CommissionerUnited States Tax Court · 1983
- Funk v. Comm'rUnited States Tax Court · 2004
199 more not listed; retrieve them via the Exa API.