Romano v. Commissioner
United States Tax Court
On Nov. 17, 1983, U.S. Customs agents seized $ 359,500 in cash from P as he and his wife were attempting to enter Canada from the United States. On the same day, R made a termination assessment against P under sec. 6851, I.R.C.
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On Nov. 17, 1983, U.S. Customs agents seized $ 359,500 in cash from P as he and his wife were attempting to enter Canada from the United States. On the same day, R made a termination assessment against P under sec. 6851, I.R.C. On Oct. 11, 1984, after P failed to file an income tax return, R mailed P a notice of deficiency for P's 1983 taxable year, which P timely petitioned to this Court on Jan. 9, 1985. The proceedings in this Court were stayed pending a criminal tax evasion charge being prosecuted against P and a forfeiture proceeding against the seized funds. R brought suit in U.S.…
1Opinion of the Court
OPINION
Wells, Judge:
The instant case is before us on respondent’s motion for summary judgment1 and motion to impose damages under section 6673. Respondent determined a deficiency in petitioner’s Federal income tax as follows:
Additions to tax
Year Deficiency Sec. 6653(a)(1) Sec. 6653(a)(2)
1983 $191,895.19 $9,594.76 1
Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.
At the time he filed the petition in the instant case, petitioner resided in New York,…
2Cases cited9 opinions
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Naftel v. CommissionerUnited States Tax Court · 1985
- Jacklin v. CommissionerUnited States Tax Court · 1982
- Laing v. United StatesSupreme Court of the United States · 1976
- Marshall v. CommissionerUnited States Tax Court · 1985
4 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
- United States v. New York State Department of Taxation & FinanceDistrict Court, W.D. New York · 2001
- Romano v. CommissionerUnited States Tax Court · 1993
- Romano v. CommissionerUnited States Tax Court · 1995