118 T.C. No. 33
UNITED STATES TAX COURT
RICHARD A. WILSON, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 13703-01. Filed June 12, 2002.
In conjunction with a criminal prosecution for tax
evasion, P executed a Plea Agreement in which he agreed
to file delinquent Federal income tax returns and
report specific amounts of income. After assessing the
tax liabilities reported on the delinquent returns, R
sent P a notice of deficiency determining only
additions to tax for fraudulent failure to file and
failure to pay estimated tax under secs. 6651(f) and
6654(a), I.R.C., respectively. P filed a petition for
redetermination. R moved to dismiss for lack of
jurisdiction, arguing that the deficiency notice was
invalid because R had not determined any “deficiency”
as defined in sec. 6211(a), I.R.C.
Held: This Court lacks jurisdiction over the
additions to tax for fraudulent failure to file because
such additions are not attributable to a deficiency.
Sec. 6665(b)(1), I.R.C.
Page: 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011