Rowlee v. Commissioner
United States Tax Court
Taxpayer, a wage earner, failed to file tax returns. No tax was withheld by his employers because he submitted W-4 forms on which he claimed either that he was exempt or that he was entitled to 10 withholding allowances. Held: The constitutional status of the Tax Court under art. I is not impacted by Northern Pipeline Construction Co. v. Marathon Pipe Line, Co., 458 U.S.
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Taxpayer, a wage earner, failed to file tax returns. No tax was withheld by his employers because he submitted W-4 forms on which he claimed either that he was exempt or that he was entitled to 10 withholding allowances. Held: The constitutional status of the Tax Court under art. I is not impacted by Northern Pipeline Construction Co. v. Marathon Pipe Line, Co., 458 U.S. (1982). Other procedural contentions and his claim that he had no duty to file returns lack merit, and the additions to tax for fraud were properly determined.
1Opinion of the Court
OPINION
Cohen, Judge:
In a notice of deficiency dated March 12, 1981, respondent determined deficiencies and additions to tax as follows:
Additions to tax
Year Deficiency sec. 6653(b)1
1977 . $1,589 $794.50
1978 . 980 490.00
1979 . 509 254.00
The only genuine controversy concerns the correctness of respondent’s determination with respect to the additions to tax. Other procedural and substantive issues are discussed, however, because the lack of merit in petitioner’s position as to each is relevant to the issue of fraud.
Factual Background
Petitioner resided in Fulton, N.Y., at the time he submitted his…
2Cases cited64 opinions
- Hoffman v. United StatesSupreme Court of the United States · 1951
- Spies v. United StatesSupreme Court of the United States · 1943
- Eisner v. MacOmberSupreme Court of the United States · 1920
- Lochner v. New YorkSupreme Court of the United States · 1905
- Helvering v. MitchellSupreme Court of the United States · 1938
59 more not listed; retrieve them via the Exa API.
3Cited by780 opinions
- Petzoldt v. CommissionerUnited States Tax Court · 1989
- Beard v. Comm'rUnited States Tax Court · 1984
- Niedringhaus v. CommissionerUnited States Tax Court · 1992
- Parks v. CommissionerUnited States Tax Court · 1990
- Hebrank v. CommissionerUnited States Tax Court · 1983
775 more not listed; retrieve them via the Exa API.