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…
1Dissent
Halpern and Holmes, JJ.,
dissenting:1 Petitioner admittedly owed almost $1 million in back taxes and additions to tax. Respondent agreed to forgo collection of almost 90 percent of that amount in exchange for petitioner’s promise to pay the balance of $100,000 in 60 days and pay additional amounts if his future income exceeded certain levels.2 Respondent expressly conditioned his forbearance on petitioner’s timely compliance with tax filing and payment requirements over the next 5 years. The majority essentially concludes that, notwithstanding petitioner’s failures to (1) comply with the…
2Cases cited31 opinions
- Camp v. PittsSupreme Court of the United States · 1973
- Florida Power & Light Co. v. LorionSupreme Court of the United States · 1985
- Bowen v. MassachusettsSupreme Court of the United States · 1988
- United States v. Kimbell Foods, Inc.Supreme Court of the United States · 1979
- Clearfield Trust Co. v. United StatesSupreme Court of the United States · 1943
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