Legal Opinion

Klein v. Comm'r

United States Tax Court

Decided October 3, 2017No. Docket Nos. 24595-15L, 24596-15LPublished

Ps, a married couple, pleaded guilty to violating I.R.C. sec. 7206(1) by filing a false return for 2006. Ps agreed to make full restitution for the losses caused by their underreporting of income for 2003-2006. At the sentencing the Government presented a Federal tax-loss calculation of $562,179 for those years. Adopting it, the District Court ordered Ps to pay that sum as restitution to the IRS.

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Ps, a married couple, pleaded guilty to violating I.R.C. sec. 7206(1) by filing a false return for 2006. Ps agreed to make full restitution for the losses caused by their underreporting of income for 2003-2006. At the sentencing the Government presented a Federal tax-loss calculation of $562,179 for those years. Adopting it, the District Court ordered Ps to pay that sum as restitution to the IRS. Ps eventually paid the full amount of restitution, along with all applicable title 18 statutory additions, and the Government released the title 18 lien that had accompanied the restitution order.…

1Opinion of the Court

ZIPORA KLEIN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent;

SAMUEL KLEIN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Klein v. Comm'r

Docket Nos. 24595-15L, 24596-15L

United States Tax Court

2017 U.S. Tax Ct. LEXIS 48; 149 T.C. No. 15;

October 3, 2017, Filed

Appropriate orders and decisions will be entered.

Ps, a married couple, pleaded guilty to violating I.R.C. sec. 7206(1) by filing a false return for 2006. Ps agreed to make full restitution for the losses caused by their underreporting of income for 2003-2006. At the sentencing the Government presented a Federal…

2Cases cited53 opinions

  1. United States v. BookerSupreme Court of the United States · 2004
  2. United States v. Mead Corp.Supreme Court of the United States · 2001
  3. Gross v. FBL Financial Services, Inc.Supreme Court of the United States · 2009
  4. Lamie v. United States TrusteeSupreme Court of the United States · 2004
  5. Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971

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