Scroggins v. Comm'r
United States Tax Court
R issued a notice of deficiency determining deficiencies in Ps' Federal income tax and accuracy-related penalties pursuant to sec. 6662(a), I.R.C., for Ps' 2004, 2005, and 2006 tax years. The tax deficiencies relate primarily to a dispute as to petitioner husband's tax residence. Held: Ps are liable for a portion of each deficiency to the extent decided herein. Held, further: Ps are liable for the applicable accuracy-related penalties.
1Opinion of the Court
THOMAS H. AND JANICE J. SCROGGINS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Scroggins v. Comm'r
Docket No. 13023-09.
United States Tax Court
T.C. Memo 2011-103; 2011 Tax Ct. Memo LEXIS 101; 101 T.C.M. (CCH) 1498;
May 18, 2011, Filed
Decision will be entered under Rule 155.
R issued a notice of deficiency determining deficiencies in Ps' Federal income tax and accuracy-related penalties pursuant to sec. 6662(a), I.R.C., for Ps' 2004, 2005, and 2006 tax years. The tax deficiencies relate primarily to a dispute as to petitioner husband's tax residence.
Held: Ps are liable for a portion…
2Cases cited29 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Freytag v. CommissionerSupreme Court of the United States · 1991
- HIGBEE v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001
- Indopco, Inc. v. CommissionerSupreme Court of the United States · 1992
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