Legal Opinion

Sachs v. Commissioner

United States Tax Court

Decided December 23, 1985No. Docket No. 27533-83Unpublished

1Opinion of the Court

RALPH G. SACHS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Sachs v. Commissioner

Docket No. 27533-83.

United States Tax Court

T.C. Memo 1985-622; 1985 Tax Ct. Memo LEXIS 11; 51 T.C.M. (CCH) 152; T.C.M. (RIA) 85622;

December 23, 1985.

Clyde B. Pritchard, for the petitioner.

Timothy S. Murphy, for the respondent.

SWIFT

MEMORANDUM FINDINGS OF FACT AND OPINION

SWIFT, Judge: In a statutory notice dated June 22, 1983, respondent determined deficiencies in petitioner's Federal income tax liabilities and additions to tax as follows:

Additions to Tax

Year

Deficiencies

I.R.C. Section 6651(a) 1

1978

$41,…

2Cases cited9 opinions

  1. Boehm v. CommissionerSupreme Court of the United States · 1945
  2. Ramsay Scarlett & Co. v. CommissionerUnited States Tax Court · 1974
  3. Ramsay Scarlett and Company, Inc. v. Commissioner of Internal Revenue, Baltimore Stevedoring Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1975
  4. Edwin Christman Dawn and June Estelle Dawn v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1982
  5. Estate of Scofield v. CommissionerUnited States Tax Court · 1956

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