Estate of Doris J. Severt, Deceased, Denise M. Harple, Executor - Page 3

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          decedent and Robert Severt for the taxable year 1993.  In the               
          notice of deficiency, respondent adjusted the income of decedent            
          and Robert Severt to reflect unreported receipts totaling $5,640.           
          Respondent determined self-employment taxes in the amount of                
          $687.  Respondent further adjusted income to reflect the                    
          allowance of a deduction for one-half of the self-employment                
          taxes so determined.                                                        
               Respondent's determinations are presumed correct, and                  
          petitioner has the burden of proving them erroneous.  Rule                  
          142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933).  Petitioner           
          presented no evidence concerning the determinations made by                 
          respondent in the notice of deficiency.  Rather, petitioner                 
          argues that respondent is barred from making an assessment for              
          the year in issue.                                                          
               As a general rule, section 6501(a) provides that any income            
          tax imposed must be assessed within 3 years after the date that             
          the taxpayer's return is filed.  As an exception to the general             
          rule, section 6501(d) provides that with certain exceptions not             
          relevant here, with respect to any income tax for which a return            
          is required in the case of a decedent, the tax shall be assessed,           
          or a proceeding in court without assessment for the collection of           
          such tax shall be begun, within 18 months after written request             
          therefor is made by the executor.                                           








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