Vincent Allen - Page 1

                                   128 T.C. No. 4                                     

                               UNITED STATES TAX COURT                                

                            VINCENT ALLEN, Petitioner v.                              
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 11016-05.               Filed March 5, 2007.                

                    P’s returns for the years at issue were false and                 
               fraudulent due to the fraudulent intent of the return                  
               preparer.  P himself did not have fraudulent intent and                
               did not file the returns with the intent to evade                      
               taxes.  R issued P a deficiency notice after the                       
               regular 3-year limitations period for assessing P’s                    
               liabilities had expired.                                               
                    Held:  The limitations period is indefinitely                     
               extended under sec. 6501(c)(1), I.R.C., if a return is                 
               fraudulent, regardless of whether the fraud was                        
               committed by the taxpayer or the taxpayer’s preparer.                  

               Forest J. Dorkowski, for petitioner.                                   
               Caroline R. Krivacka, for respondent.                                  

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