Legal Opinion

James R. Brown & Opal Freeman v. Commissioner

United States Tax Court

Decided June 21, 2018No. 4900-15Unpublished

1Opinion of the Court

T.C. Memo. 2018-91

UNITED STATES TAX COURT JAMES R. BROWN AND OPAL FREEMAN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 4900-15. Filed June 21, 2018. Kacie N.C. Dillon, for petitioners. Michael R. Harrel, for respondent. MEMORANDUM OPINION ASHFORD, Judge: By statutory notice of deficiency dated November 24, 2014, respondent determined deficiencies of $5,538 and $20,394 in petitioners’ Federal income tax for the 2009 and 2010 taxable years, respectively. In this same notice of deficiency, respondent also determined additions to tax pursuant to -2- [*2] section…

2Cases cited14 opinions

  1. Naftel v. CommissionerUnited States Tax Court · 1985
  2. U.S. Titan, Inc. v. Guangzhou Zhen Hua Shipping Co., Ltd.Court of Appeals for the Second Circuit · 2001
  3. Breman v. CommissionerUnited States Tax Court · 1976
  4. Kronish v. CommissionerUnited States Tax Court · 1988
  5. Estate of Young v. CommissionerUnited States Tax Court · 1983

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