Rios v. Comm'r
United States Tax Court
P failed to timely file tax returns for his 2003, 2005, 2006, and 2007 tax years. R prepared substitutes for returns and issued notices of deficiency determining P had received unreported income and was liable for income tax deficiencies and additions to tax under I.R.C. secs. 6651(a)(1) and (2) and 6654. Held: Respondent's determinations are sustained.
1Opinion of the Court
ARMANDO RIOS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Rios v. Comm'r
Docket No. 3861-09
United States Tax Court
T.C. Memo 2012-128; 2012 Tax Ct. Memo LEXIS 126; 103 T.C.M. (CCH) 1713;
May 2, 2012, Filed
Decision will be entered for respondent.
P failed to timely file tax returns for his 2003, 2005, 2006, and 2007 tax years. R prepared substitutes for returns and issued notices of deficiency determining P had received unreported income and was liable for income tax deficiencies and additions to tax under I.R.C. secs. 6651(a)(1) and (2) and 6654.
Held: Respondent's determinations are…
2Cases cited12 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
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- Commissioner v. HeiningerSupreme Court of the United States · 1943
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