Legal Opinion

Colestock v. Commissioner

United States Tax Court

Decided March 1, 1994No. Docket No. 15398-91Published

R determined a deficiency in Ps' Federal income tax for 1984 relying on sec. 6501(e)(1)(A), I.R.C., which provides for a 6-year period of limitations where the taxpayer omits from gross income an amount properly includable therein that is in excess of 25 percent of the amount of gross income stated in the return.

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R determined a deficiency in Ps' Federal income tax for 1984 relying on sec. 6501(e)(1)(A), I.R.C., which provides for a 6-year period of limitations where the taxpayer omits from gross income an amount properly includable therein that is in excess of 25 percent of the amount of gross income stated in the return. R subsequently was granted leave to file an amendment to answer out of time to assert an increased deficiency and additions to tax attributable to the disallowance of a depreciation deduction claimed on Ps' 1984 return. Ps filed a motion for partial summary judgment that the…

1Opinion of the Court

Stephen G. Colestock and Susan F. Colestock, Petitioners v. Commissioner of Internal Revenue, Respondent

Colestock v. Commissioner

Docket No. 15398-91

United States Tax Court

102 T.C. 380; 1994 U.S. Tax Ct. LEXIS 13; 102 T.C. No. 12;

March 1, 1994, Filed

An order denying petitioners' motion for partial summary judgment will be issued.

R determined a deficiency in Ps' Federal income tax for 1984 relying on sec. 6501(e)(1)(A), I.R.C., which provides for a 6-year period of limitations where the taxpayer omits from gross income an amount properly includable therein that is in excess of 25 percent of the…

2Cases cited20 opinions

  1. United States v. American Trucking AssociationsSupreme Court of the United States · 1940
  2. Naftel v. CommissionerUnited States Tax Court · 1985
  3. Badaracco v. CommissionerSupreme Court of the United States · 1984
  4. Zaentz v. CommissionerUnited States Tax Court · 1988
  5. Reis v. CommissionerUnited States Tax Court · 1942

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