Legal Opinion

Michael C. Worsham v. Commissioner

United States Tax Court

Decided October 1, 2019No. 26210-16Unpublished

1Opinion of the Court

T.C. Memo. 2019-132

UNITED STATES TAX COURT MICHAEL C. WORSHAM, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 26210-16. Filed October 1, 2019. Michael C. Worsham, pro se. David A. Indek and Nancy M. Gilmore, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION COLVIN, Judge: In a notice of deficiency issued December 8, 2016, respondent determined that petitioner is liable for deficiencies and additions to tax in the following amounts: -2- [*2] Additions to tax Sec. Sec. Sec. Year Deficiency 6651(a)(1) 6651(a)(2) 6654(a) 2005 $47,537 $121 $134 $1,907 2007 9,578 2,155…

2Cases cited6 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Warner M. Larsen v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1985
  3. Thomas v. Mercantile Nat. Bank at DallasCourt of Appeals for the Fifth Circuit · 1953
  4. Baral v. United StatesSupreme Court of the United States · 2000
  5. Deaton v. CommissionerCourt of Appeals for the Fifth Circuit · 2006

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