James L. Ball - Page 1

            T.C. Memo. 1995-520                                                                         



                                     UNITED STATES TAX COURT                                            


                                  JAMES L. BALL, Petitioner v.                                          
                         COMMISSIONER OF INTERNAL REVENUE, Respondent                                   


                  Docket No. 1647-93.              Filed October 31, 1995.                              


                        P filed late returns for 1984, 1985, and 1986.  R                               
                  examined P's returns and assessed: (1) The amounts                                    
                  shown on them and additional amounts for 1984 and 1985,                               
                  (2) additions to tax for failure to timely file returns                               
                  and pay tax for 1984, 1985, and 1986, and (3) interest                                
                  for 1984, 1985, and 1986.                                                             
                        R improperly assessed tax in amounts greater than                               
                  reported on P's 1984 and 1985 returns without issuing a                               
                  notice of deficiency.  Later, R abated assessment of                                  
                  the amounts in excess of the amounts reported on P's                                  
                  returns for 1984 and 1985, and also additions to tax                                  
                  and interest for 1984, 1985, and 1986.  R's Examination                               
                  Division and P reached an agreement on P's case for                                   
                  1984, 1985, and 1986.  R's Office of Appeals Division                                 
                  (Appeals) did not consider the case.  P seeks an award                                
                  of administrative costs under sec. 7430, I.R.C.                                       







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