Legal Opinion
Seibly v. Commissioner
United States Tax Court
Decided March 20, 1991No. Docket No. 30276-89UnpublishedCited by 1 opinion
1Opinion of the Court
RALPH SEIBLY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Seibly v. Commissioner
Docket No. 30276-89
United States Tax Court
T.C. Memo 1991-125; 1991 Tax Ct. Memo LEXIS 143; 61 T.C.M. (CCH) 2201; T.C.M. (RIA) 91125;
March 20, 1991, Filed
Decision will be entered for the respondent.
George D. Humphreys, for the petitioner.
William Reese, for the respondent.
RUWE, Judge.
RUWE
MEMORANDUM OPINION
Respondent determined a deficiency in petitioner's 1983 Federal income tax and additions to tax as follows:
Additions to Tax
Deficiency
Sec. 6651(a) 1
Sec. 6653(a)(1)
Sec. 6653(a)(2)
Sec. 6661
$ 10,000
$ 1,736
2Cases cited7 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Neely v. CommissionerUnited States Tax Court · 1985
- Pallottini v. CommissionerUnited States Tax Court · 1988
- Emmons v. CommissionerUnited States Tax Court · 1989
- Gary M. Emmons and Martha C. Emmons v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1990
2 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Kathryn D. Ehrmann v. CommissionerUnited States Tax Court · 2014