T.C. Memo. 1996-1
UNITED STATES TAX COURT
WALTON A. SUTHERLAND, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 5780-92, 21777-93, Filed January 2, 1996.
592-94.
R determined deficiencies based on, among other
theories, P’s failure to report as income legal fees
that P, an attorney, earned in 1987.
1. Held, P’s oral motion to shift the burden of
proof is denied.
2. Held, further, P’s oral motion to dismiss in
petitioner’s favor the 1987 year because the 3-year
period of limitations on assessment and collection for
that year has expired is denied.
3. Held, further, P earned the fee in question in
1987.
4. Held, further, R’s determinations of additions
to tax under sec. 6653(a)(1)(A) and (B), I.R.C., for
1987 are sustained.
5. Held, further, R’s determination of an
addition to tax under sec. 6661, I.R.C., for 1987 is
sustained.
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