Shea v. Commissioner
United States Tax Court
P and his wife filed joint returns for 1990 and 1991. P submitted a delinquent return for 1992 that was filed as a joint return. R determined that P underreported business receipts for 1990, 1991, and 1992 based on deposits to P's bank accounts and also disallowed business deductions claimed on P's returns. In the notice of deficiency for 1992, R determined that P's proper filing status for 1992 was married filing separately.
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P and his wife filed joint returns for 1990 and 1991. P submitted a delinquent return for 1992 that was filed as a joint return. R determined that P underreported business receipts for 1990, 1991, and 1992 based on deposits to P's bank accounts and also disallowed business deductions claimed on P's returns. In the notice of deficiency for 1992, R determined that P's proper filing status for 1992 was married filing separately. Even though P and his wife remained married throughout 1992, R did not allocate one-half of P's income for 1992 to P's wife pursuant to California community property…
1Opinion of the Court
JOHN D. SHEA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Shea v. Commissioner
No. 10841-95, No. 23549-96
United States Tax Court
112 T.C. 183; 1999 U.S. Tax Ct. LEXIS 17; 112 T.C. No. 14;
April 1, 1999, Filed
Decision will be entered under Rule 155.
P and his wife filed joint returns for 1990 and 1991. P submitted a delinquent return for 1992 that was filed as a joint return. R determined that P underreported business receipts for 1990, 1991, and 1992 based on deposits to P's bank accounts and also disallowed business deductions claimed on P's returns. In the notice of deficiency for…
2Cases cited27 opinions
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Indopco, Inc. v. CommissionerSupreme Court of the United States · 1992
- Commissioner v. HeiningerSupreme Court of the United States · 1943
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