Legal Opinion

Crocker v. Commissioner

United States Tax Court

Decided May 8, 1989No. Docket No. 27245-86PublishedCited by 136 opinions

Petitioners, who are calendar year taxpayers, requested and received automatic extensions of time within which to file their 1981 and 1982 returns. Petitioners filed their 1981 and 1982 returns after April 15th but within the due date, as extended.

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Petitioners, who are calendar year taxpayers, requested and received automatic extensions of time within which to file their 1981 and 1982 returns. Petitioners filed their 1981 and 1982 returns after April 15th but within the due date, as extended. Respondent determined that petitioners were liable for additions to tax under sec. 6651(a)(1), I.R.C. 1954, for failure to make a timely return for 1981 and 1982 on the basis that the applications for extensions of time were invalid because petitioners failed to comply with the Income Tax Regulations and, therefore, any extensions resulting…

1Opinion of the Court

SCOTT, Judge:

Respondent determined additions to petitioners’ income taxes for the years and in the amounts as follows:

_Additions to tax_

Year Sec. 6651(a)(1)1 Sec. 6653(a)(1) Sec. 6653(a)(2)

1981 $8,329.33 $3,506.88 *

1982 5,261.97 2,484.09 *

The issues for decision are: (1) Whether petitioners are hable for additions to tax under section 6651(a)(1) because they failed to timely file their Federal income tax returns for each of the years 1981 and 1982; (2) whether petitioners are hable for additions to tax under section 6653(a)(1) and section 6653(a)(2) for the years 1981 and 1982 because their…

2Cases cited21 opinions

  1. United States v. BoyleSupreme Court of the United States · 1985
  2. Carlos and Jacqueline Marcello v. Commissioner of Internal Revenue, Joseph, Jr. And Anastasia Marcello v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1967
  3. Electric & Neon, Inc. v. CommissionerUnited States Tax Court · 1971
  4. Fischer v. CommissionerUnited States Tax Court · 1968
  5. Bemis Bro. Bag Co. v. United StatesSupreme Court of the United States · 1933

16 more not listed; retrieve them via the Exa API.

3Cited by136 opinions

  1. Clayton v. CommissionerUnited States Tax Court · 1994
  2. Estate of La Meres v. Comm'rUnited States Tax Court · 1992
  3. Condor Int'l v. CommissionerUnited States Tax Court · 1992
  4. Risman v. CommissionerUnited States Tax Court · 1993
  5. Merriam v. CommissionerUnited States Tax Court · 1995

131 more not listed; retrieve them via the Exa API.

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