Odend'Hal v. Commissioner
United States Tax Court
R determined that Ps were liable for late filing additions to tax under I.R.C. sec. 6651(a)(1) for 1977 through 1979 and increased interest under I.R.C. sec. 6621(c) for 1977 through 1982. Ps timely filed petitions for redetermination of R's determinations. R filed motions to dismiss for lack of jurisdiction as to I.R.C. sec. 6621(c) interest.
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R determined that Ps were liable for late filing additions to tax under I.R.C. sec. 6651(a)(1) for 1977 through 1979 and increased interest under I.R.C. sec. 6621(c) for 1977 through 1982. Ps timely filed petitions for redetermination of R's determinations. R filed motions to dismiss for lack of jurisdiction as to I.R.C. sec. 6621(c) interest. Held, this Court does not have jurisdiction to determine whether Ps are liable for I.R.C. sec. 6621(c) interest because late filing additions to tax under I.R.C. sec. 6651(a)(1) are not deficiencies which are substantial underpayments attributable to…
1Opinion of the Court
OPINION
NlMS, Chief Judge:
This case is before the Court on respondent’s motions to dismiss for lack of jurisdiction as to section 6621(c). (Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue. Section 7721(b) of the Omnibus Budget Reconciliation Act of 1989, Pub. L. 101-239, 103 Stat. 2106, 2399, repealed section 6621(c) effective for returns the due date of which (determined without regard to extensions) is after December 31, 1989.)
Petitioner Fortune Odend’hal, Jr. IV (petitioner) invested in the so-called Kroger-Cincinnati…
2Cases cited11 opinions
- Commissioner v. Gooch Milling & Elevator Co.Supreme Court of the United States · 1944
- Southern Pacific Transp. Co. v. CommissionerUnited States Tax Court · 1980
- Woods v. CommissionerUnited States Tax Court · 1989
- Judge v. CommissionerUnited States Tax Court · 1987
- Odend'hal v. CommissionerUnited States Tax Court · 1983
6 more not listed; retrieve them via the Exa API.
3Cited by37 opinions
- Meyer v. CommissionerUnited States Tax Court · 1991
- Powell v. CommissionerUnited States Tax Court · 1991
- Bourekis v. Comm'rUnited States Tax Court · 1998
- Pen Coal Corp. v. CommissionerUnited States Tax Court · 1996
- Estate of Magarian v. CommissionerUnited States Tax Court · 1991
32 more not listed; retrieve them via the Exa API.