HIGBEE v. COMMISSIONER OF INTERNAL REVENUE
United States Tax Court
Ps filed a petition seeking redeterminations of R's disallowance of several deductions and imposition of an addition to tax and accuracy-related penalty. The parties settled most of the issues regarding the disallowed deductions except one regarding certain Schedule C deductions.
Read the full summary
Ps filed a petition seeking redeterminations of R's disallowance of several deductions and imposition of an addition to tax and accuracy-related penalty. The parties settled most of the issues regarding the disallowed deductions except one regarding certain Schedule C deductions. At trial, Ps claimed additional deductions on account of a casualty loss, charitable contributions, unreimbursed employee expenses, and Schedule C and E expenses that were neither claimed by Ps on their tax returns nor raised in the notice of deficiency. The examination in the instant case took place after the…
1Opinion of the Court
OPINION
Vasquez, Judge:
Respondent determined the following deficiencies in, addition to, and accuracy-related penalty on petitioners’ 1996 and 1997 Federal income taxes:
Addition to tax Penalty Year Deficiency sec. 6651(a)(1) sec. 6662(a)
$10,796 $2,669 M CO co
12,443 - - - $2,488.60 h-1 CO co
Unless otherwise stated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.
After concessions, we must decide whether petitioners are entitled to the following deductions: (1) $1,328 for a…
2Cases cited7 opinions
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Indopco, Inc. v. CommissionerSupreme Court of the United States · 1992
- Hradesky v. CommissionerUnited States Tax Court · 1975
- Petzoldt v. CommissionerUnited States Tax Court · 1989
- Frank J. Hradesky v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1976
2 more not listed; retrieve them via the Exa API.
3Cited by1,284 opinions
- Wheeler v. Comm'rUnited States Tax Court · 2006
- Chai v. CommissionerCourt of Appeals for the Second Circuit · 2017
- Swain v. Comm'rUnited States Tax Court · 2002
- Cabirac v. Comm'rUnited States Tax Court · 2003
- Whitehouse Hotel Ltd. Partnership v. CommissionerCourt of Appeals for the Fifth Circuit · 2010
1,279 more not listed; retrieve them via the Exa API.