Wiksell v. Commissioner
United States Tax Court
1. R asserted increased deficiencies for 1984 and 1985 and fraud on the part of D in the filing of the returns for those years. The allegations of fraud were well pleaded. In the face of repeated notices, D failed to participate in the preparation for trial, nor did he appear in person or by counsel at trial.
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1. R asserted increased deficiencies for 1984 and 1985 and fraud on the part of D in the filing of the returns for those years. The allegations of fraud were well pleaded. In the face of repeated notices, D failed to participate in the preparation for trial, nor did he appear in person or by counsel at trial. Held: R's increased deficiencies and additions to tax for fraud sustained as to D. 2. M, D's spouse, claimed the innocent spouse protection of sec. 6013(e), I.R.C., and also claimed that no valid joint tax returns were filed because 1984 and 1985 returns were signed by her under duress.…
1Opinion of the Court
DAVID L. WIKSELL AND MARGARET WIKSELL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Wiksell v. Commissioner
Docket No. 11752-91
United States Tax Court
T.C. Memo 1994-99; 1994 Tax Ct. Memo LEXIS 100; 67 T.C.M. (CCH) 2360; T.C.M. (RIA) 94099;
March 9, 1994, Filed
An appropriate Order of Dismissal and Decision will be entered as to petitioner David L. Wiksell.
Decision will be entered under Rule 155 as to petitioner Margaret Wiksell.
1. R asserted increased deficiencies for 1984 and 1985 and fraud on the part of D in the filing of the returns for those years. The allegations of fraud…
2Cases cited20 opinions
- Rowlee v. CommissionerUnited States Tax Court · 1983
- Robert W. Bradford v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1986
- Petzoldt v. CommissionerUnited States Tax Court · 1989
- Habersham-Bey v. CommissionerUnited States Tax Court · 1982
- Hebrank v. CommissionerUnited States Tax Court · 1983
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3Cited by3 opinions
- Margaret Wiksell v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1996
- In Re HinckleyUnited States Bankruptcy Court, M.D. Florida · 2000
- Margaret Wiksell v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1996