Guillermo Baez Espinosa - Page 1

                                   107 T.C. No. 9                                     

                               UNITED STATES TAX COURT                                

                       GUILLERMO BAEZ ESPINOSA, Petitioner v.                         
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 8900-94.                Filed September 24, 1996.           

                    P, a nonresident alien individual, failed to file                 
               Federal income tax returns for the years 1987 through 1991.            
               R repeatedly notified P of his failure to file.  R prepared            
               substitute returns for P and notified P that pursuant to               
               sec. 874(a), I.R.C., no deductions were allowable.  P                  
               subsequently submitted returns claiming the benefit of                 
               deductions.  R then issued a notice of deficiency.  Held: P            
               is not entitled to the benefit of deductions pursuant to               
               sec. 874(a), I.R.C.  Held, further, P is liable for                    
               additions to tax pursuant to secs. 6651(a)(1) and 6654,                

               John P. Bender, for petitioner.                                        
               Joni D. Larson, for respondent.                                        

Page:   1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011