Hall v. Commissioner
United States Tax Court
Petitioner (P) was involved in a number of businesses, most of which were incorporated. P reported on his tax returns large business losses for the years in issue, most of which appear to arise from expenses of his corporations. P had gross receipts, interest, and royalty income in excess of what he reported on his tax returns. P filed his tax returns for 1982 through 1986 late.
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Petitioner (P) was involved in a number of businesses, most of which were incorporated. P reported on his tax returns large business losses for the years in issue, most of which appear to arise from expenses of his corporations. P had gross receipts, interest, and royalty income in excess of what he reported on his tax returns. P filed his tax returns for 1982 through 1986 late. Respondent mailed a notice of deficiency to P less than 3 years after any of these tax returns were filed. This notice of deficiency was returned by the U.S. Postal Service. P wrote to respondent, stating that any…
1Opinion of the Court
WILBURN C. HALL, JR., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Hall v. Commissioner
Docket No. 26125-90.
United States Tax Court
T.C. Memo 1996-27; 1996 Tax Ct. Memo LEXIS 29; 71 T.C.M. (CCH) 1869;
January 25, 1996, Filed
Decision will be entered under Rule 155.
Petitioner (P) was involved in a number of businesses, most of which were incorporated. P reported on his tax returns large business losses for the years in issue, most of which appear to arise from expenses of his corporations. P had gross receipts, interest, and royalty income in excess of what he reported on his tax…
2Cases cited54 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Neely v. CommissionerUnited States Tax Court · 1985
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