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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