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,
I.R.C.
John P. Bender, for petitioner.
Joni D. Larson, for respondent.
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