Legal Opinion

BAGBY v. COMMISSIONER OF INTERNAL REVENUE

United States Tax Court

Decided April 12, 1994No. Docket Nos. 18538-90, 18796-90, 18865-90PublishedCited by 1 opinion

After filing petitions, T failed to respond to R's informal communications. Until 2 days before trial, T failed to respond to most of R's formal communications and failed to comply with the Court's orders to respond.

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After filing petitions, T failed to respond to R's informal communications. Until 2 days before trial, T failed to respond to most of R's formal communications and failed to comply with the Court's orders to respond. T provided purported copies of joint returns that he alleged he and his wife (W), had filed for 1985, 1986, and 1987. T signed W's name on the returns that he had allegedly filed for 1985 and 1986. T represented to R and testified at trial that those signatures were W's. T altered copies of checks and represented to R and testified that the altered copies were true copies of…

1Opinion of the Court

Beghe, Judge:

Respondent determined the following deficiencies in and additions to petitioner’s Federal income tax:

Additions to tax

Year Deficiency Sec. 6651(a) Sec. 6653(a) Sec. 6654(a)

1985 $17,085 $2,375 1$854 4^ co

1986 23,748 4,353 Oi

1987 22,830 2,145 11,142 to

All section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

In three separate statutory notices, respondent determined that petitioner failed to file tax returns for the years in issue and determined deficiencies and additions to…

2Cases cited30 opinions

  1. Spies v. United StatesSupreme Court of the United States · 1943
  2. Rowlee v. CommissionerUnited States Tax Court · 1983
  3. Stone v. CommissionerUnited States Tax Court · 1971
  4. Otsuki v. CommissionerUnited States Tax Court · 1969
  5. Chris D. Stoltzfus and Irma H. Stoltzfus v. United StatesCourt of Appeals for the Third Circuit · 1968

25 more not listed; retrieve them via the Exa API.

3Cited by1 opinion

  1. BAGBY v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 1994

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