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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