Heasley v. Commissioner
United States Tax Court
1. Respondent's determination of loss carryover sustained for failure of proof by petitioner. 2. An amount properly assessed against petitioner as income tax prior to issuance of notice of deficiency and not subsequently abated does not constitute a portion of the statutory deficiency under the definition of deficiency contained in section 6211, I.R.C. 1954. 3. The evidence shows that petitioner derived income from the sale of grain in the amount of $ 3,591.53 in the year…
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1. Respondent's determination of loss carryover sustained for failure of proof by petitioner. 2. An amount properly assessed against petitioner as income tax prior to issuance of notice of deficiency and not subsequently abated does not constitute a portion of the statutory deficiency under the definition of deficiency contained in section 6211, I.R.C. 1954. 3. The evidence shows that petitioner derived income from the sale of grain in the amount of $ 3,591.53 in the year 1960. 4. A Federal income tax return filed on Form 1040 for the calendar year 1959 in the name of petitioner and her…
1Opinion of the Court
Selma Heasley, Petitioner, v. Commissioner of Internal Revenue, Respondent
Heasley v. Commissioner
Docket Nos. 3044-63, 1240-64
United States Tax Court
45 T.C. 448; 1966 U.S. Tax Ct. LEXIS 141;
February 21, 1966, Filed
Decisions will be entered under Rule 50.
1. Respondent's determination of loss carryover sustained for failure of proof by petitioner.
2. An amount properly assessed against petitioner as income tax prior to issuance of notice of deficiency and not subsequently abated does not constitute a portion of the statutory deficiency under the definition of deficiency contained in section 6211,…
2Cases cited6 opinions
- Avery v. CommissionerSupreme Court of the United States · 1934
- M. G. STOLLER, Magdalene Stoller, Kenneth M. Stoller and Ellsworth J. Stoller v. the UNITED STATESUnited States Court of Claims · 1963
- Heasley v. CommissionerUnited States Tax Court · 1966
- Hastings & Co. v. SmithCourt of Appeals for the Third Circuit · 1955
- Fleming v. CommissionerUnited States Tax Court · 1959
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