Feller v. Commissioner
United States Tax Court
P overstated his prepayment credits on his Federal income tax returns in order to claim refunds for 1992 through 1997. On Nov. 22, 2006, R issued two notices of deficiency determining that P was subject to the fraud penalty of I.R.C. sec. 6663 because his overstated prepayment credits resulted in underpayments of income tax pursuant to I.R.C. sec. 6664 and sec. 1.6664-2(c)(1) and (g), Example (3), Income Tax Regs.
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P overstated his prepayment credits on his Federal income tax returns in order to claim refunds for 1992 through 1997. On Nov. 22, 2006, R issued two notices of deficiency determining that P was subject to the fraud penalty of I.R.C. sec. 6663 because his overstated prepayment credits resulted in underpayments of income tax pursuant to I.R.C. sec. 6664 and sec. 1.6664-2(c)(1) and (g), Example (3), Income Tax Regs. On Nov. 27, 2006, R assessed, by use of the mathematical error assessment procedures of I.R.C. sec. 6213(b)(1), adjustments related to P's overstatement of prepayment credits for…
1Opinion of the Court
RICK D. FELLER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Feller v. Comm'r
Docket No. 4325-07
United States Tax Court
135 T.C. 497; 2010 U.S. Tax Ct. LEXIS 41; 135 T.C. No. 25;
November 8, 2010, Filed
P overstated his prepayment credits on his Federal income tax returns in order to claim refunds for 1992 through 1997. On Nov. 22, 2006, R issued two notices of deficiency determining that P was subject to the fraud penalty of I.R.C. sec. 6663 because his overstated prepayment credits resulted in underpayments of income tax pursuant to I.R.C. sec. 6664 and sec. 1.6664-2(c)(1) and (g),…
Also in this document: Concurrence; Dissent · Wherry; Dissent · Gustafson.
2Cases cited15 opinions
- Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
- Whitman v. American Trucking Assns., Inc.Supreme Court of the United States · 2001
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- King v. St. Vincent's HospitalSupreme Court of the United States · 1991
- Badaracco v. CommissionerSupreme Court of the United States · 1984
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