Goff v. Commissioner
United States Tax Court
R may proceed with collection of tax liability and civil penalties for filing frivolous tax returns. 1. Held: Submission of a "Bonded Promissory Note" of P's husband was not payment of liabilities and penalties. 2. Held, further, P is subject to sanction under sec. 6673(a)(1), I.R.C., for procedures instituted primarily for delay, etc.
1Opinion of the Court
Halpern, Judge:
This case is before the Court to determine whether respondent may proceed with the collection of petitioner’s unpaid Federal income tax for 1996 through 2006 and unpaid civil penalties for filing frivolous income tax returns for 1997, 1999, 2000, 2003, and 2004 (collectively, petitioner’s liabilities or, simply, the liabilities). We review the determinations under section 6330(d)(1).
All section references are to the Internal Revenue Code of 1986, as amended and as applicable to this case, and all Rule references are to the Tax Court Rules of Practice and Procedure unless…
2Cases cited8 opinions
- Lucas v. Pilliod Lumber Co.Supreme Court of the United States · 1930
- Jonson v. Comm'rUnited States Tax Court · 2002
- Jonson v. CommissionerCourt of Appeals for the Tenth Circuit · 2003
- Mendes v. Comm'rUnited States Tax Court · 2003
- Landry v. CommissionerUnited States Tax Court · 2001
3 more not listed; retrieve them via the Exa API.
3Cited by10 opinions
- Rader v. CommissionerUnited States Tax Court · 2014
- Winslow v. CommissionerUnited States Tax Court · 2012
- Kernan v. Comm'rUnited States Tax Court · 2014
- Clark J. Gebman & Rebecca Gebman v. CommissionerUnited States Tax Court · 2017
- Gebman v. Comm'rUnited States Tax Court · 2017
5 more not listed; retrieve them via the Exa API.