Judge v. Commissioner
United States Tax Court
Petitioners filed their returns for the years 1976 and 1978 in 1980 and 1982, respectively. In 1982, respondent determined additions to tax pursuant to secs. 6651(a)(1), 6651(a)(2), and 6654, I.R.C. 1954, based upon the tax liabilities shown on the return for 1978. Respondent then audited petitioners' returns for 1976 and 1978 and, in 1983, petitioners signed a Form 4549, Income Tax Examination Changes, agreeing to the Commissioner's determination of deficiencies in tax for…
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Petitioners filed their returns for the years 1976 and 1978 in 1980 and 1982, respectively. In 1982, respondent determined additions to tax pursuant to secs. 6651(a)(1), 6651(a)(2), and 6654, I.R.C. 1954, based upon the tax liabilities shown on the return for 1978. Respondent then audited petitioners' returns for 1976 and 1978 and, in 1983, petitioners signed a Form 4549, Income Tax Examination Changes, agreeing to the Commissioner's determination of deficiencies in tax for both of the years. Petitioners, however, objected to the Commissioner's determination of further additions to tax based…
1Opinion of the Court
CLAPP, Judge:
By notice of deficiency dated May 1, 1984, respondent determined, pursuant to section 6651(a)(1),1 the following additions to petitioners’ Federal income taxes:
Taxable year Addition
1976.$778.68
1978. 949.87
Subsequently, respondent amended his answer to place in dispute additions to tax pursuant to section 6653(a) in the amounts of $155.54 and $2,779.72 for the years 1976 and 1978, respectively.
The issues for decision are:(1) Whether this Court has jurisdiction over additions to tax under section 6651(a)(1) for failure to timely file returns and section 6651(a)(2) for failure to…
2Cases cited8 opinions
- Huntsberry v. CommissionerUnited States Tax Court · 1984
- Breman v. CommissionerUnited States Tax Court · 1976
- Estate of Young v. CommissionerUnited States Tax Court · 1983
- Medeiros v. CommissionerUnited States Tax Court · 1981
- Estate of Baumgardner v. CommissionerUnited States Tax Court · 1985
3 more not listed; retrieve them via the Exa API.
3Cited by89 opinions
- Crocker v. CommissionerUnited States Tax Court · 1989
- 508 Clinton St. Corp. v. CommissionerUnited States Tax Court · 1987
- Cooper v. Comm'rUnited States Tax Court · 2010
- Barton v. CommissionerUnited States Tax Court · 1991
- Savage v. CommissionerUnited States Tax Court · 1999
84 more not listed; retrieve them via the Exa API.