Wheeler v. Comm'r
United States Tax Court
P failed to timely file Federal income tax returns for the 1994, 1995, 1996, 1997, 1998, 1999, 2000, and 2001 taxable years. R determined deficiencies and additions to tax, which P then contested on the basis of tax protester arguments. Held: P is liable for the deficiencies determined by R, for additions to tax under secs. 6651(a)(1) and 6654, I.R.C., and for a penalty under sec. 6673, I.R.C.
1Opinion of the Court
CHARLES RAYMOND WHEELER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Wheeler v. Comm'r
Nos. 14430-03, 7206-04
United States Tax Court
T.C. Memo 2006-109; 2006 Tax Ct. Memo LEXIS 110; 91 T.C.M. (CCH) 1194; RIA TM 56527;
May 22, 2006, Filed
P failed to timely file Federal income tax returns for the 1994,
1995, 1996, 1997, 1998, 1999, 2000, and 2001 taxable years. R
determined deficiencies and additions to tax, which P then
contested on the basis of tax protester arguments.
Held: P is liable for the deficiencies determined by R,
for additions to tax under secs. 6651(a)(1) and 6654, I.R.C.,
and…
2Cases cited25 opinions
- HIGBEE v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001
- United States v. BoyleSupreme Court of the United States · 1985
- Bill Johnson's Restaurants, Inc. v. National Labor Relations BoardSupreme Court of the United States · 1983
- Vincent C. Wiley v. United States of America Citizens Federal Mortgage Corporation State of Ohio Franklin County Treasurer and Houng ThaiCourt of Appeals for the Sixth Circuit · 1994
- Greenberg's Express, Inc. v. CommissionerUnited States Tax Court · 1974
20 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Wheeler v. Comm'rUnited States Tax Court · 2006