Peters v. Commissioner
United States Tax Court
Held, the Commissioner failed to carry his burden of proving that the petitioners executed consents extending the statute of limitations in this case.
1Opinion of the Court
GARRY L. and LOUISE E. PETERS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Peters v. Commissioner
Docket No. 9920-77.
United States Tax Court
T.C. Memo 1978-219; 1978 Tax Ct. Memo LEXIS 293; 37 T.C.M. (CCH) 941; T.C.M. (RIA) 78219;
June 12, 1978, Filed
Held, the Commissioner failed to carry his burden of proving that the petitioners executed consents extending the statute of limitations in this case.
Charles L. Abrahams, for the petitioners.
Arthur A. Oshiro, for the respondent.
SIMPSON
MEMORANDUM OPINION
SIMPSON, Judge: The Commissioner determined a deficiency of $ 3,502.00 in the…
2Cases cited8 opinions
- Robinson v. CommissionerUnited States Tax Court · 1972
- Hotel Equities Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1976
- Farmers Feed Co. v. CommissionerUnited States Board of Tax Appeals · 1928
- United States v. Juanita C. Gurley, Formerly Juanita C. HillCourt of Appeals for the Fifth Circuit · 1969
- Hotel Equities Corp. v. CommissionerUnited States Tax Court · 1975
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