Legal Opinion

McConnell v. Comm'r

United States Tax Court

Decided July 14, 2008No. 13063-06Unpublished

R determined that Ps are liable for additions to tax pursuant to secs. 6653(a)(1) and (2) and 6661(a), I.R.C., for their 1983 taxable year. Held: Ps are liable for the additions to tax.

1Opinion of the Court

NORMAN J. AND PAULA A. MCCONNELL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

McConnell v. Comm'r

No. 13063-06

United States Tax Court

T.C. Memo 2008-167; 2008 Tax Ct. Memo LEXIS 169; 95 T.C.M. (CCH) 10;

July 14, 2008, Filed

Utah Jojoba I Research v. Commissioner, T.C. Memo 1998-6, 1998 Tax Ct. Memo LEXIS 3 (T.C., 1998)

R determined that Ps are liable for additions to tax pursuant to secs. 6653(a)(1) and (2) and 6661(a), I.R.C., for their 1983 taxable year.

Held: Ps are liable for the additions to tax.

Anthony V. Diosdi and Anita Steburg, for petitioners.

Andrew R. Moore, for respondent.

2Cases cited23 opinions

  1. United States v. BoyleSupreme Court of the United States · 1985
  2. Neely v. CommissionerUnited States Tax Court · 1985
  3. Carlos and Jacqueline Marcello v. Commissioner of Internal Revenue, Joseph, Jr. And Anastasia Marcello v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1967
  4. Marcello v. CommissionerUnited States Tax Court · 1964
  5. Snow v. CommissionerSupreme Court of the United States · 1974

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