Conklin v. Commissioner
United States Tax Court
P and T, husband and wife, filed joint returns for the years at issue. R issued to T a notice of deficiency covering items 1, 2, 3, 4, and 5. T paid the deficiencies.
Read the full summary
P and T, husband and wife, filed joint returns for the years at issue. R issued to T a notice of deficiency covering items 1, 2, 3, 4, and 5. T paid the deficiencies. Subsequently, R issued a notice of deficiency to P covering items 1 through 5 identical to those in the notice to T, and items 6, 7, 8, and 9. Before trial, R conceded, with respect to P, items 2, 3, 6, 7, 8, and 9, and the parties settled item 4. Held, the Court is not deprived of jurisdiction by the payments by T, nor by the parties' resolution of some of the items. Item 1 involved charitable contribution deductions P claimed…
1Opinion of the Court
FAY, Judge:
Respondent determined deficiencies in and additions to petitioner’s Federal income tax as follows:
Additions to tax
Year Section Deficiency 6653(a)1 Section 6653(a)(1) Section 6653(a)(2)
1979 $7,601 $380
1980 9,220 461
1981 9,800 --- . $490 i1)
This case was tried on September 18 and 19, 1986. On August 24, 1987, an opinion was issued by this Court, Conklin v. Commissioner, T.C. Memo. 1987-411, pursuant to which decision was to be entered in accordance with Rule 155. There is confusion by the parties concerning the computation to be made under such Rule. For that reason, this Court has,…
2Cases cited28 opinions
- Wong Sun v. United StatesSupreme Court of the United States · 1963
- Welch v. HelveringSupreme Court of the United States · 1933
- Nix v. WilliamsSupreme Court of the United States · 1984
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
23 more not listed; retrieve them via the Exa API.
3Cited by6 opinions
- Mary Ann Tavery v. United StatesCourt of Appeals for the Tenth Circuit · 1990
- William T. Conklin v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1990
- Conklin v. CommissionerUnited States Tax Court · 1988
- Kroh v. CommissionerUnited States Tax Court · 1992
- Kroh v. CommissionerUnited States Tax Court · 1992
1 more not listed; retrieve them via the Exa API.