Higbee v. Commissioner of Internal Revenue
- Decided
- June 6, 2001
- Docket
- No. 14035-99
- Status
- Published
- Jurisdiction
- Federal
Cited 2,507 timesNo negative treatment found in this library
What later courts said
- holding that, in a situation such as here, the taxpayer bears the burden of proof with regard to issues of reasonable cause — Clary Hood, Inc. (2022)
- holding that the IRS must produce "sufficient evidence indicating that it is appropriate to impose the * * * penalty", but the IRS need not introduce evidence on exceptions to the penalty — Bigdeli v. Comm'r (2013)
- holding that taxpayers bear the burden of proof relating to reasonable cause — Vercel v. Comm'r (2014)
Each line is a later court’s own words about this case, not a summary. Read the opinion before relying on it.
How the opinion begins
OPINION Vasquez, Judge:
Respondent determined the following deficiencies in, addition to, and accuracy-related penalty on petitioners’ 1996 and 1997 Federal income taxes:
Addition to tax Penalty Year Deficiency sec. 6651(a)(1) sec. 6662(a) $10,796 $2,669 M CO co 12,443 - - - $2,488.60 h-[1] CO co Unless otherwise stated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.
Cite this
Higbee v. Commissioner of Internal Revenue, 116 T.C. 438 (2001)Read the full opinion
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