Williams v. Commissioner
United States Tax Court
P mailed two Forms 1040, U.S. Individual Income Tax Return, for 1991 to the IRS. The first Form 1040 included a deduction for "Non Taxable Compensation" equal to P's total income, and P failed to sign it. P stipulated that this Form 1040 is not a valid return.
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P mailed two Forms 1040, U.S. Individual Income Tax Return, for 1991 to the IRS. The first Form 1040 included a deduction for "Non Taxable Compensation" equal to P's total income, and P failed to sign it. P stipulated that this Form 1040 is not a valid return. In the second Form 1040, P reported taxes owed of $ 36,621. P however attached a disclaimer statement to the second Form 1040 stating that he denied all tax liability and did not admit that the stated amount of tax was due. HELD: P is liable for the deficiency. HELD, FURTHER, P's second Form 1040 is not a valid return; therefore, P is…
1Opinion of the Court
OPINION
VASQUEZ, Judge:
Respondent determined a deficiency of $42,934, an addition to tax pursuant to section 6651(a)(1) of $9,492, and an accuracy-related penalty pursuant to section 6662(a) of $8,587 in petitioner’s 1991 Federal income tax.1
Pursuant to Rule 122, the parties submitted this case fully stipulated. The stipulations of fact, the supplemental stipulations of fact, and the attached exhibits are incorporated herein by this reference. At the time the petition was filed, petitioner resided in Spring, Texas.
After concessions,2 the issues for decision are: (1) Whether petitioner is…
2Cases cited18 opinions
- United States v. BoyleSupreme Court of the United States · 1985
- Badaracco v. CommissionerSupreme Court of the United States · 1984
- Cupp v. CommissionerUnited States Tax Court · 1975
- Glenn Crain v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1984
- Norman E. Coleman v. Commissioner of Internal Revenue, Gary Holder v. Secretary of the Treasury and United States of AmericaCourt of Appeals for the Seventh Circuit · 1986
13 more not listed; retrieve them via the Exa API.
3Cited by61 opinions
- Wheeler v. Comm'rUnited States Tax Court · 2006
- Cabirac v. Comm'rUnited States Tax Court · 2003
- United States v. Mark Kevin HicksCourt of Appeals for the Ninth Circuit · 2000
- United States v. Thurston Paul BellCourt of Appeals for the Third Circuit · 2005
- Takaba v. Comm'rUnited States Tax Court · 2002
56 more not listed; retrieve them via the Exa API.