Lardas v. Commissioner
United States Tax Court
R determined deficiencies on account of the disallowance of losses deriving from Ps' interests in two grantor trusts. R's notices of deficiency were issued within the period for assessing deficiencies against Ps, but more than 3 years after the grantor trusts filed their respective information returns. At the times the deficiency notices were issued, no consent to extend the period for assessment against either trust was in effect.
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R determined deficiencies on account of the disallowance of losses deriving from Ps' interests in two grantor trusts. R's notices of deficiency were issued within the period for assessing deficiencies against Ps, but more than 3 years after the grantor trusts filed their respective information returns. At the times the deficiency notices were issued, no consent to extend the period for assessment against either trust was in effect. Held: R's notices of deficiency were timely issued. Sec. 6501(a), I.R.C., proscribing assessment after 3 years following the filing of "the return", refers to the…
1Opinion of the Court
OPINION
Halpern, Judge:
Respondent, by means of several notices of deficiency, determined deficiencies in income tax, additions to tax, and increased interest, as follows:
John A. and Shirley R. Lardas — Docket No. 29363-89
Additions to tax and increased interest
Year Deficiency Sec. 6663 (a)(1) Sec. 6661 Sec. 6621(c)
1983 $69,295 1$3,464.75 $17,324 2
1985 49.043 1.lS 11.603 2
Angelo A. and Janet M. Lardas• — Docket No. 30368-89
Additions to tax and increased interest
Year Deficiency Sec. 6653(a)(1) Sec. 6661 Sec. 6621(c) Sec. 6651(a)(1)
1983 $14,857 1$743 $3,714 2
1984 19,642 1982 4,911 2
1985 47,766…
2Cases cited14 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
- Commissioner v. Lane-Wells Co.Supreme Court of the United States · 1944
- Germantown Trust Co. v. CommissionerSupreme Court of the United States · 1940
- Lawrence v. CommissionerUnited States Tax Court · 1957
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