Ulloa v. Comm'r
United States Tax Court
P received wages and other income in 2003-2006 from third-party payers who reported the income to the IRS. P filed untimely"zero returns", reporting no income and no tax liability.
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P received wages and other income in 2003-2006 from third-party payers who reported the income to the IRS. P filed untimely"zero returns", reporting no income and no tax liability. Pursuant to I.R.C. sec. 6020(b), R prepared substitutes for returns for 2003-2006 on the basis of the third-party payer information and issued notices of deficiency determining taxes owed and additions to tax under I.R.C. secs. 6651(a)(1) and (2) and 6654(a). P filed petitions and contends that the third parties are not "valid payers" because they do not reside in Puerto Rico, the Virgin Island, Guam, or American…
1Opinion of the Court
RICHARD ENRIQUE ULLOA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Ulloa v. Comm'r
Nos. 2053-09, 4514-09
United States Tax Court
T.C. Memo 2010-68; 2010 Tax Ct. Memo LEXIS 67; 99 T.C.M. (CCH) 1280;
April 6, 2010, Filed
P received wages and other income in 2003-2006 from third-party payers who reported the income to the IRS. P filed untimely"zero returns", reporting no income and no tax liability. Pursuant to I.R.C. sec. 6020(b), R prepared substitutes for returns for 2003-2006 on the basis of the third-party payer information and issued notices of deficiency determining taxes owed…
2Cases cited27 opinions
- Haines v. KernerSupreme Court of the United States · 1972
- HIGBEE v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001
- United States v. BoyleSupreme Court of the United States · 1985
- Brushaber v. Union Pacific RailroadSupreme Court of the United States · 1916
- Rowlee v. CommissionerUnited States Tax Court · 1983
22 more not listed; retrieve them via the Exa API.
3Cited by11 opinions
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- Gibson v. Comm'rUnited States Tax Court · 2014
- Norman v. Comm'rUnited States Tax Court · 2016
- Peter E. Hendrickson & Doreen M. Hendrickson v. CommissionerUnited States Tax Court · 2019
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