Discussion Question - Accounting
PLEASE REPLY TO THE DISCUSSION IN YOUR OWN WORDS. ANSWER EACH QUESTION.
APA FORMAT.Week 2 discussion
Bruner vs Commissioner
For this weeks discussion, read the tax law case in the hyperlink above (click on the link). For your response, please address the following:
1. What were your initial impression of the taxpayer?
2. In your opinion, do you believe that the taxpayer had a reasonable basis for his arguments?
3. Why do you believe the taxpayer took his case this far into court? Do you believe he had a motive? If so, what do you think it was?
4. Do you agree with the judges ruling? Why or why not?
5. Do you believe this was a frivolous case? Why or why not?| About LexisNexis | Privacy Policy | Terms & Conditions | Copyright © 2021 LexisNexis
Date and Time: Tuesday, March 9, 2021 11:01:00 PM EST
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1. BRUNER v. COMMISSIONER, 1998 Tax Ct. Memo LEXIS 246
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BRUNER v. COMMISSIONER
United States Tax Court
July 6, 1998, Filed
Tax Ct. Dkt. No. 23790-90
Reporter
1998 Tax Ct. Memo LEXIS 246 *; T.C. Memo 1998-246; 76 T.C.M. (CCH) 40
ROSS WILLIAM BRUNER, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent
Disposition: [*1] An appropriate order will be issued
and a decision will be entered for respondent.
Case Summary
Procedural Posture
Respondent Commissioner of Internal Revenue (IRS)
determined deficiencies in petitioner taxpayers 1987
and 1988 federal income taxes and determined that the
taxpayer was liable for penalties under I.R.C. §
6651(a)(1) for failing to report income, penalties under
I.R.C. § 6653(a)(1) for negligence; and penalties under
I.R.C. § 6654(a) for failure to make estimated income
tax payments for 1987 and 1988.
Overview
The IRS received reports from the taxpayers employer,
a pension provider, and a securities brokerage firm that
the taxpayer had received, respectively, wages, a
pension, and had sold securities, receiving income from
the sale. The taxpayer did not file federal income tax
returns for 1987 and 1988.The IRS determined a
deficiency in, additions to, and penalties on, his federal
income taxes and the taxpayer sought a
redetermination. In response to numerous questions by
counsel for the IRS, the taxpayer declined to offer any
testimony relevant to the determination of his income for
1987 and 1988. His response to each question was I
stand in silence. The court sustained the determination
of the IRS and held that the taxpayer failed to prove any
error in its determinations. The court held that that the
taxpayer failed to prove that his failure to file tax returns
was not due to willful neglect or that such failure was
due to reasonable cause. The court found that the
reporting payers withheld taxes from the taxpayers
income sources and that the neither taxpayer made any
estimated tax payments for 1987 or 1988, nor showed
that any of the statutory exceptions were applicable.
Outcome
The court sustained the determinations of the IRS,
which determined deficiencies in, additions to, and
penalties on, the taxpayers 1987 and 1988 federal
income taxes.
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