Philip S. Morgan v. Commissioner of Internal Revenue

WELLFORD, Circuit Judge.

This is an appeal from a decision of the Tax Court, T.C. Memo 1984-384, which held that certain Forms 1040 filed by Morgan, the taxpayer-appellant, did not qualify as federal income tax returns, that attempted elections by Morgan to file joint returns at a later time were ineffective, and that certain penalties and additions to the taxes determined to be due were appropriate because mitigation provisions did not apply under the circumstances. We affirm.

A. Background

Respondent-appellee Commissioner determined deficiencies in income tax plus additions to the tax pursuant…