Gary M. Emmons and Martha C. Emmons v. Commissioner of Internal Revenue

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• finding that untimely filed returns were considered filed on the date that such returns were received by the IRS
• filing untimely returns without an adequate and reasonable excuse or justification for the delinquent filing is sufficient for the imposition of the negligence addition
• where the Commissioner has the burden of proving negligence, failure to file establishes a prima facie case for the Commissioner that the taxpayer was negligent, which the taxpayer may rebut with evidence tending to show the failure to file was not negligent

Source: CourtListener parenthetical corpus (CC0).