Castillo v. Commissioner
United States Tax Court
Petitioner, a wage earner, failed to file Federal income tax returns for the taxable years 1975, 1976, 1977, and 1978. His Federal income tax liability was underpaid because he filed false Form W-4 certificates with his employer, and because he failed to pay estimated tax.
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Petitioner, a wage earner, failed to file Federal income tax returns for the taxable years 1975, 1976, 1977, and 1978. His Federal income tax liability was underpaid because he filed false Form W-4 certificates with his employer, and because he failed to pay estimated tax. Petitioner was convicted of willful failure to file an income tax return for the taxable year 1977, a violation of sec. 7203, I.R.C. 1954. Held, the additions to tax for fraud and failure to pay estimated tax are imposed. Held, further, petitioner is collaterally estopped by his criminal conviction under sec. 7203, I.R.C.…
1Opinion of the Court
Goffe, Judge:
The Commissioner determined deficiencies in petitioner’s Federal income taxes for the taxable years 1973, 1975, 1976, 1977, and 1978 and additions to tax under section 6651(a),1 6653(a), 6653(b), 6654, and 6682(a) as follows:
Year Deficiency Sec. 6651(a) Sec. 6653(a) Sec. 6653(b) Sec. 6654 Sec. 6682(a)
1973 $1,749 $57.79 $87.45 0 0 0
1975 2,600 0 0 $1,300.00 $64.21 $50
1976 3,565 0 0 1,782.50 82.79 50
1977 2,950 0 0 i;475.00 104.61 50
1978 3,973 0 0 1,986.50 95.26 50
After concessions,2 the issues for decision are: (1) Whether petitioner failed to report income for each of the taxable…
2Cases cited26 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Spies v. United StatesSupreme Court of the United States · 1943
- Rowlee v. CommissionerUnited States Tax Court · 1983
- Stone v. CommissionerUnited States Tax Court · 1971
- Gajewski v. CommissionerUnited States Tax Court · 1976
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3Cited by88 opinions
- Niedringhaus v. CommissionerUnited States Tax Court · 1992
- Kotmair v. CommissionerUnited States Tax Court · 1986
- Miller v. CommissionerUnited States Tax Court · 1990
- Weber v. Comm'rUnited States Tax Court · 2004
- Mazzocchi Bus Co. v. CommissionerUnited States Tax Court · 1993
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