Patronik-Holder v. Commissioner
United States Tax Court
At the time the notice of deficiency was mailed, neither P nor her spouse had filed any Federal income tax returns for 1988. R's notice of deficiency issued solely to P for 1988 determined a $ 5,437 income tax deficiency, based upon salary and wages of $ 30,757.66 which P had earned. The notice allowed a $ 4,186 credit for withholding prepayments, with a balance of $ 1,251 owing in tax, plus additions to tax pursuant to secs. 6651(a)(1) and 6653(a)(1), I.R.C.
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At the time the notice of deficiency was mailed, neither P nor her spouse had filed any Federal income tax returns for 1988. R's notice of deficiency issued solely to P for 1988 determined a $ 5,437 income tax deficiency, based upon salary and wages of $ 30,757.66 which P had earned. The notice allowed a $ 4,186 credit for withholding prepayments, with a balance of $ 1,251 owing in tax, plus additions to tax pursuant to secs. 6651(a)(1) and 6653(a)(1), I.R.C. In the answer to the petition, R increased the deficiency to $ 10,510; reduced the sec. 6651(a)(1) addition to tax to $ 100; increased…
1Opinion of the Court
OPINION
Dawson, Judge:
This case was assigned to Special Trial Judge D. Irvin Couvillion pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.1 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
Couvillion, Special Trial Judge:
Respondent determined a deficiency of $5,437 in petitioner’s Federal income tax for 1988 and additions to tax under section 6651(a)(1) of $312.75 and under section 6653(a)(1) of $271.85. In the answer to the petition, respondent claimed an increased deficiency of…
2Cases cited11 opinions
- Neely v. CommissionerUnited States Tax Court · 1985
- Bixby v. CommissionerUnited States Tax Court · 1972
- Reiff v. CommissionerUnited States Tax Court · 1981
- Emmons v. CommissionerUnited States Tax Court · 1989
- Gary M. Emmons and Martha C. Emmons v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1990
6 more not listed; retrieve them via the Exa API.
3Cited by14 opinions
- Robin & Diane Miller, Husband and Wife v. United StatesCourt of Appeals for the Ninth Circuit · 1994
- Robert F. Lundy v. Internal Revenue ServiceCourt of Appeals for the Fourth Circuit · 1995
- Daoust v. CommissionerUnited States Tax Court · 1994
- Bennett v. CommissionerUnited States Tax Court · 1994
- Boecking v. CommissionerUnited States Tax Court · 1993
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