Galuska v. Commissioner
United States Tax Court
P had not filed a Form 1040, U.S. Individual Income Tax Return, for 1986 nor a claim for credit or refund of 1986 tax as of the date of mailing of a deficiency notice to him, Apr. 12, 1990. P actually overpaid his 1986 tax through withholding and a $ 20,000 estimated tax payment made when filing a Form 4868, Application for Automatic Extension of Time to File U.S.
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P had not filed a Form 1040, U.S. Individual Income Tax Return, for 1986 nor a claim for credit or refund of 1986 tax as of the date of mailing of a deficiency notice to him, Apr. 12, 1990. P actually overpaid his 1986 tax through withholding and a $ 20,000 estimated tax payment made when filing a Form 4868, Application for Automatic Extension of Time to File U.S. Individual Income Tax Return, on Apr. 15, 1987. P subsequently filed a Form 2688, Application for Additional Extension of Time to File U.S. Individual Income Tax Return, on Aug. 15, 1987, to extend his time to file to Oct. 15, 1987.…
1Opinion of the Court
Richard J. Galuska, Petitioner v. Commissioner of Internal Revenue, Respondent
Galuska v. Commissioner
Docket No. 15609-90
United States Tax Court
98 T.C. 661; 1992 U.S. Tax Ct. LEXIS 49; 98 T.C. No. 45;
June 22, 1992, Filed
Decision will be entered under Rule 155.
P had not filed a Form 1040, U.S. Individual Income Tax Return, for 1986 nor a claim for credit or refund of 1986 tax as of the date of mailing of a deficiency notice to him, Apr. 12, 1990. P actually overpaid his 1986 tax through withholding and a $ 20,000 estimated tax payment made when filing a Form 4868, Application for Automatic…
2Cases cited15 opinions
- Badaracco v. CommissionerSupreme Court of the United States · 1984
- Beard v. Comm'rUnited States Tax Court · 1984
- Florsheim Brothers Drygoods Co. v. United StatesSupreme Court of the United States · 1930
- Commissioner v. Lane-Wells Co.Supreme Court of the United States · 1944
- Zellerbach Paper Co. v. HelveringSupreme Court of the United States · 1934
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