Legal Opinion
George E. Joseph v. Commissioner
United States Tax Court
Decided May 19, 2020No. 27759-15Unpublished
1Opinion of the Court
T.C. Memo. 2020-65
UNITED STATES TAX COURT GEORGE E. JOSEPH, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 27759-15. Filed May 19, 2020. R issued a notice of deficiency for P's 2011, 2012, and 2013 taxable years on the basis of substitutes for returns (SFRs) prepared under I.R.C. sec. 6020(b)(1). Thereafter, P filed or otherwise provided R with returns for those years in which he claimed deductions from partnerships and S corporations. The parties executed a stipulation of settled issues in which P agreed that he had recognizable capital gain and other income for the…
2Cases cited9 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- HIGBEE v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001
- Helvering v. R. J. Reynolds Tobacco Co.Supreme Court of the United States · 1939
- Wilkinson v. CommissionerUnited States Tax Court · 1979
- Swain v. Comm'rUnited States Tax Court · 2002
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