Dolan v. Commissioner
United States Tax Court
1. Petitioner's claim that her signatures on 1957 and 1958 Federal income tax returns headed "John T. & Marie A. Dolan" were forged or procured by fraud is rejected. Accordingly, the returns are joint returns of petitioner and John T. Dolan. 2. On June 29, 1962, John T. Dolan filed with respondent a waiver of restrictions on assessments and collection of certain deficiencies in 1957 and 1958 income taxes; on August 31, 1962, such deficiencies were assessed against John.
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1. Petitioner's claim that her signatures on 1957 and 1958 Federal income tax returns headed "John T. & Marie A. Dolan" were forged or procured by fraud is rejected. Accordingly, the returns are joint returns of petitioner and John T. Dolan. 2. On June 29, 1962, John T. Dolan filed with respondent a waiver of restrictions on assessments and collection of certain deficiencies in 1957 and 1958 income taxes; on August 31, 1962, such deficiencies were assessed against John. Held, the assessments against John did not prevent respondent from subsequently sending to petitioner a valid statutory…
1Opinion of the Court
Forrester, Judge:
Respondent has determined deficiencies in income tas and additions to tax against petitioner as follows:
Year Income tax Additions to tax Seo. 6653(a) Sec. 6651(a)[1]
1957.. 1958.. $3,925.49 2,871.32 $196.27 166.48 $287.13
The following issues are presented: (1) Did petitioner file joint returns with John T. Dolan for the years 1957 and 1958? (2) If petitioner filed joint returns with John T. Dolan for 1957 and 1958, does the fact that respondent assessed deficiencies against John T. Dolan bar respondent from subsequently proceeding against petitioner with respect to the same…
Also in this document: Concurrence.
2Cases cited26 opinions
- Bull v. United StatesSupreme Court of the United States · 1935
- United States v. PriceSupreme Court of the United States · 1960
- Lusthaus v. CommissionerSupreme Court of the United States · 1946
- Hanover Bank v. CommissionerSupreme Court of the United States · 1962
- Howell v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1949
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3Cited by88 opinions
- Abeles v. CommissionerUnited States Tax Court · 1988
- Rodney v. Comm'rUnited States Tax Court · 1969
- Benjamin v. CommissionerUnited States Tax Court · 1976
- Davenport v. CommissionerUnited States Tax Court · 1967
- Cluck v. CommissionerUnited States Tax Court · 1995
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