Gene L. Moretti 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.

• affirming a Tax Court ruling excluding from evidence documents from a pro se taxpayer not produced in compliance with the standing pretrial order and stating: \[T]he Tax Court acted within its discretion in excluding the documents.\
• notice of deficiency “carries a presumption of correctness requiring the taxpayer to prove by a preponderance of the evidence that the Commissioner’s determination was erroneous”
• “A notice of deficiency is ... considered the jurisdictional prerequisite to a taxpayer’s suit in the Tax Court for rede-termination of his tax liability.” (internal quotation marks omitted)
• taxpayer's failure to timely file a tax return precluded subsequently claiming an NOL carryforward without the NOL's being absorbed, to the extent required, by the carryback year
• taxpayer's failure to timely file a tax return precluded subsequently claiming a net operating loss carryforward without the net operating losses' being absorbed, to the extent required, by the carryback year

Source: CourtListener parenthetical corpus (CC0).