Koufman v. Commissioner
United States Tax Court
After entry of decision, the Commissioner moved to amend his answer to claim an increased deficiency on the ground that the claim therefor was made "at or before the hearing or a rehearing" within the meaning of sec. 6214(a), I.R.C. 1954. Held, such claim was not made "at or before the hearing."
1Opinion of the Court
OPINION
Simpson, Judge:
On October 28, 1976, this Court filed its Memorandum Findings of Fact and Opinion in this case (T.C. Memo. 1976-330). Therein, we found that, inter alia, a $16,752 corporate distribution in 1968 by Koufman Construction Co. of Boston to the petitioners was a dividend under section 301 of the Internal Revenue Code of 1954.1 However, we withheld entry of our decision to give the parties an opportunity to submit computations in accordance with Rule 155, Tax Court Rules of Practice and Procedure.2 On July 19,1977, we filed a Supplemental Memorandum Opinion (T.C. Memo.…
2Cases cited17 opinions
- Robert A. Henningsen, and Cross and R.A. And Margaret Henningsen v. Commissioner of Internal Revenue, AndCourt of Appeals for the Fourth Circuit · 1957
- Haft Trust v. CommissionerUnited States Tax Court · 1974
- Robin Haft Trust v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1975
- Helvering v. Edison Securities CorporationCourt of Appeals for the Fourth Circuit · 1935
- Commissioner of Internal Revenue v. Erie Forge Co.Court of Appeals for the Third Circuit · 1948
12 more not listed; retrieve them via the Exa API.
3Cited by36 opinions
- Scar v. CommissionerUnited States Tax Court · 1983
- Estate of Young v. CommissionerUnited States Tax Court · 1983
- Graff v. CommissionerUnited States Tax Court · 1980
- Law v. CommissionerUnited States Tax Court · 1985
- Estate of Petschek v. CommissionerUnited States Tax Court · 1983
31 more not listed; retrieve them via the Exa API.