Legal Opinion

Robinson v. Comm'r

United States Tax Court

Decided September 5, 2002No. 9574-99Published

P-H operated a law practice as a sole proprietorship at all relevant times. R audited Ps' 1987 joint tax return and made several adjustments to the Schedules A and C attached to this tax return. Ps agreed to R's adjustments and the resulting deficiencies and additions to tax. In 1994, R seized real property that Ps owned; in 1995, R sold the property and applied the proceeds to Ps' underpayment of their 1987 income tax liability and interest thereon.

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P-H operated a law practice as a sole proprietorship at all relevant times. R audited Ps' 1987 joint tax return and made several adjustments to the Schedules A and C attached to this tax return. Ps agreed to R's adjustments and the resulting deficiencies and additions to tax. In 1994, R seized real property that Ps owned; in 1995, R sold the property and applied the proceeds to Ps' underpayment of their 1987 income tax liability and interest thereon. On Schedule C of their 1995 joint tax return, Ps deducted the 1987 underpayment interest that had been thus paid. 1. Held: Insofar as sec.…

1Opinion of the Court

EDWARD A. ROBINSON III AND DIANA R. ROBINSON, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Robinson v. Comm'r

No. 9574-99

United States Tax Court

119 T.C. 44; 2002 U.S. Tax Ct. LEXIS 41; 119 T.C. No. 4;

September 5, 2002, Filed

Decision for the government.

P-H operated a law practice as a sole proprietorship at all

relevant times. R audited Ps' 1987 joint tax return and made

several adjustments to the Schedules A and C attached to this

tax return. Ps agreed to R's adjustments and the resulting

deficiencies and additions to tax. In 1994, R seized real

property that Ps owned; in 1995, R sold…

Also in this document: Concurrence · Ruwe; Concurrence · Thornton; Dissent · Wells; Dissent · Swift; Dissent · Vasquez.

2Cases cited94 opinions

  1. Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
  2. Skidmore v. Swift & Co.Supreme Court of the United States · 1944
  3. United States v. Mead Corp.Supreme Court of the United States · 2001
  4. Russello v. United StatesSupreme Court of the United States · 1983
  5. Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971

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