Miller v. Commissioner
United States Tax Court
Petitioner husband (M) pled guilty to a charge of income tax evasion, sec. 7201, I.R.C. 1954, and conspiracy, 18 U.S.C. sec. 2 (1982), for 1983. M was sentenced to prison, given probation, and fined for his actions. R determined Federal income tax deficiencies and additions to tax under secs. 6653(b) and 6661, I.R.C. 1954, as well as the increased rate of interest under sec. 6621(c), I.R.C. 1954, for 1983 arising from petitioners' fraudulent interest deductions.
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Petitioner husband (M) pled guilty to a charge of income tax evasion, sec. 7201, I.R.C. 1954, and conspiracy, 18 U.S.C. sec. 2 (1982), for 1983. M was sentenced to prison, given probation, and fined for his actions. R determined Federal income tax deficiencies and additions to tax under secs. 6653(b) and 6661, I.R.C. 1954, as well as the increased rate of interest under sec. 6621(c), I.R.C. 1954, for 1983 arising from petitioners' fraudulent interest deductions. Petitioners contend that imposition of these additions to tax and the increased rate of interest are precluded as to M by the Double…
1Opinion of the Court
FRANKLIN S. MILLER, JR. AND HELEN B. MILLER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Miller v. Commissioner
Docket No. 2174-91
United States Tax Court
T.C. Memo 1994-249; 1994 Tax Ct. Memo LEXIS 243; 67 T.C.M. (CCH) 3042;
May 31, 1994, Filed
Decision will be entered in accordance with the parties' stipulations as to amounts.
Petitioner husband (M) pled guilty to a charge of income tax evasion, sec. 7201, I.R.C. 1954, and conspiracy, 18 U.S.C. sec. 2 (1982), for 1983. M was sentenced to prison, given probation, and fined for his actions. R determined Federal income tax…
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