Winslow v. Commissioner
United States Tax Court
P filed no tax return for either 2005 or 2006. R prepared substitutes for returns and issued notices of deficiency for those years. P principally argues that he is not liable for the deficiencies because the individuals who prepared the substitutes for returns and issued the notices of deficiency were not delegated authority to do so.
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P filed no tax return for either 2005 or 2006. R prepared substitutes for returns and issued notices of deficiency for those years. P principally argues that he is not liable for the deficiencies because the individuals who prepared the substitutes for returns and issued the notices of deficiency were not delegated authority to do so. R also determined additions to tax for failure to timely file a return and failure to timely pay tax due and asks that we sanction P for making frivolous arguments. 1. Held: The individuals who certified the substitutes for returns and issued the notices of…
1Opinion of the Court
Halpern, Judge:
By notices of deficiency dated May 9, 2011 (notices), respondent determined deficiencies in, and additions to, petitioner’s 2005 and 2006 Federal income tax as follows:
Additions to tax
Year Deficiency Sec. 6651(a)(1) Sec. 6651(a)(2)
$2,706 cn co to CD LO O O Cd
2,491 ^ o L-a M CD O O <N
Petitioner assigned error to those determinations, averring only: “The true amount of the tax and interest and penalties owing is $0.00.” Petitioner did not, as required by our standing pretrial order, file a pretrial memorandum, which, among other things, would have described his view of the issues…
2Cases cited10 opinions
- HIGBEE v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001
- Glenn Crain v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1984
- Charles G. Fargo Elizabeth A. Fargo v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2006
- Vallone v. CommissionerUnited States Tax Court · 1987
- Fargo v. Comm'rUnited States Tax Court · 2004
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3Cited by6 opinions
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- Craig S. Walquist & Maria L. Walquist v. CommissionerUnited States Tax Court · 2019
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