Robinette v. Comm'r
United States Tax Court
On Oct. 31, 1995, P and R entered into an offer-in-compromise. The terms of the offer-in-compromise required P to, among other things, timely file his 1995 through 1999 tax returns. On the morning of Oct. 15, 1999, the day P's 1998 return was due, P's accountant (A) prepared P's return. That afternoon, A drove to P's office to obtain P's signature on P's return. A returned to his office.
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On Oct. 31, 1995, P and R entered into an offer-in-compromise. The terms of the offer-in-compromise required P to, among other things, timely file his 1995 through 1999 tax returns. On the morning of Oct. 15, 1999, the day P's 1998 return was due, P's accountant (A) prepared P's return. That afternoon, A drove to P's office to obtain P's signature on P's return. A returned to his office. Thereafter, A affixed postage to the envelope containing P's return using a private postage meter. A deposited the envelope containing P's return in a U.S. Postal Service mailbox in his office building. R's…
1Opinion of the Court
VASQUEZ, Judge:
This case was commenced in response to a Notice of Determination Concerning Collection Action(s) Under Sections 63201 and/or 6330. The issue is whether respondent may proceed with collection of petitioner’s 1983, 1984, 1985, 1986, 1987, 1988, 1989, 1990, and 1991 tax liabilities.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. The stipulation of facts, first supplemental stipulation of facts, second supplemental stipulation of facts, and the attached exhibits are incorporated herein by this reference. At the time he filed the petition, petitioner resided…
2Cases cited46 opinions
- Bowen v. MassachusettsSupreme Court of the United States · 1988
- Goza v. CommissionerUnited States Tax Court · 2000
- Sego v. CommissionerUnited States Tax Court · 2000
- Thor Power Tool Co. v. CommissionerSupreme Court of the United States · 1979
- United States v. LombardoSupreme Court of the United States · 1916
41 more not listed; retrieve them via the Exa API.
3Cited by88 opinions
- Murphy v. Comm'rUnited States Tax Court · 2005
- James M. Robinette v. Commissioner of the Internal Revenue ServiceCourt of Appeals for the Eighth Circuit · 2006
- Olsen v. United StatesCourt of Appeals for the First Circuit · 2005
- Speltz v. Comm'rUnited States Tax Court · 2005
- Porter v. Comm'rUnited States Tax Court · 2008
83 more not listed; retrieve them via the Exa API.