Legal Opinion

Clark v. Commissioner

United States Tax Court

Decided October 1, 1991No. Docket No. 1872-89Unpublished

P filed false Forms W-4 claiming exemption from Federal income tax and failed to file Federal income tax returns for the taxable years 1981 through 1986. P claims that his wages are not income. Held, P is liable for the deficiencies as set forth in R's notice of deficiency. Held further, P is liable for the additions to tax for fraud as set forth in the notice of deficiency.

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P filed false Forms W-4 claiming exemption from Federal income tax and failed to file Federal income tax returns for the taxable years 1981 through 1986. P claims that his wages are not income. Held, P is liable for the deficiencies as set forth in R's notice of deficiency. Held further, P is liable for the additions to tax for fraud as set forth in the notice of deficiency. Held further, P is liable for the additions to tax for failing to file estimated tax with proper adjustments to reflect any withholding credits to which P is entitled under I.R.C. sec. 31. Held further, petitioner is…

1Opinion of the Court

JIMMY PAUL CLARK, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Clark v. Commissioner

Docket No. 1872-89

United States Tax Court

T.C. Memo 1991-496; 1991 Tax Ct. Memo LEXIS 545; 62 T.C.M. (CCH) 917; T.C.M. (RIA) 91496;

October 1, 1991, Filed

Decision will be entered under Rule 155.

P filed false Forms W-4 claiming exemption from Federal income tax and failed to file Federal income tax returns for the taxable years 1981 through 1986. P claims that his wages are not income. Held, P is liable for the deficiencies as set forth in R's notice of deficiency. Held further, P is liable for the…

2Cases cited7 opinions

  1. Neely v. CommissionerUnited States Tax Court · 1985
  2. Habersham-Bey v. CommissionerUnited States Tax Court · 1982
  3. Hebrank v. CommissionerUnited States Tax Court · 1983
  4. Stratton v. CommissionerUnited States Tax Court · 1970
  5. Professional Services v. CommissionerUnited States Tax Court · 1982

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