Abrams v. Commissioner
United States Tax Court
Petitioner instituted this proceeding claiming that his wages are not income subject to tax. Held, in these circumstances, respondent's determinations of income tax deficiencies and additions to the tax under secs. 6651(a), 6653(a), and 6654, I.R.C. 1954 as amended, are sustained.
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Petitioner instituted this proceeding claiming that his wages are not income subject to tax. Held, in these circumstances, respondent's determinations of income tax deficiencies and additions to the tax under secs. 6651(a), 6653(a), and 6654, I.R.C. 1954 as amended, are sustained. Held, further, on the Court's own motion, damages are awarded to the United States in the amount of $ 5,000 since petitioner's position in this proceeding is frivolous and groundless and this proceeding was instituted and maintained primarily for delay. Sec. 6673, I.R.C. 1954 as amended.
1Opinion of the Court
OPINION
Dawson, Chief Judge:
This case was assigned pursuant to Delegation Order No. 8 of this Court, 81 T.C. XXV (1983), to Special Trial Judge Francis J. Cantrel for the purpose of considering and ruling on respondent’s motion for judgment on the pleadings filed herein. After a review of the record, we agree with and adopt his opinion which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
Cantrel, Special Trial Judge: This case is before the Court on respondent’s motion for judgment on the pleadings filed on September 29, 1983, pursuant to Rule 120, Tax Court Rules of Practice and…
2Cases cited33 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
- Brushaber v. Union Pacific RailroadSupreme Court of the United States · 1916
- Rowlee v. CommissionerUnited States Tax Court · 1983
- Greenberg's Express, Inc. v. CommissionerUnited States Tax Court · 1974
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3Cited by201 opinions
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- Gregory T. Granado v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1986
- Horn v. CommissionerUnited States Tax Court · 1988
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