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    David and Donna L. Huggins v. Commissioner of Internal Revenue, 101 F.3d 684, 2d Cir. (1996)

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    The document summarizes a court case in which David and Donna Huggins appealed a ruling of the United States Tax Court regarding their income taxes for 1992. The summary indicates that the Hugginses incorrectly filed non-resident alien tax forms instead of regular tax forms, failed to report all their income, and made various tax protestor arguments claiming their income was not taxable. The Tax Court found for the Commissioner and the appellate court affirmed, rejecting the Hugginses' arguments as frivolous.

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    David and Donna L. Huggins v. Commissioner of Internal Revenue, 101 F.3d 684, 2d Cir. (1996)

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    The document summarizes a court case in which David and Donna Huggins appealed a ruling of the United States Tax Court regarding their income taxes for 1992. The summary indicates that the Hugginses incorrectly filed non-resident alien tax forms instead of regular tax forms, failed to report all their income, and made various tax protestor arguments claiming their income was not taxable. The Tax Court found for the Commissioner and the appellate court affirmed, rejecting the Hugginses' arguments as frivolous.

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    Filed: 1996-05-15 Precedential Status: Non-Precedential Citations: 101 F.3d 684 Docket: 95-4221

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    The document summarizes a court case in which David and Donna Huggins appealed a ruling of the United States Tax Court regarding their income taxes for 1992. The summary indicates that the Hugginses incorrectly filed non-resident alien tax forms instead of regular tax forms, failed to report all their income, and made various tax protestor arguments claiming their income was not taxable. The Tax Court found for the Commissioner and the appellate court affirmed, rejecting the Hugginses' arguments as frivolous.

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    18 views2 pages

    David and Donna L. Huggins v. Commissioner of Internal Revenue, 101 F.3d 684, 2d Cir. (1996)

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    The document summarizes a court case in which David and Donna Huggins appealed a ruling of the United States Tax Court regarding their income taxes for 1992. The summary indicates that the Hugginses incorrectly filed non-resident alien tax forms instead of regular tax forms, failed to report all their income, and made various tax protestor arguments claiming their income was not taxable. The Tax Court found for the Commissioner and the appellate court affirmed, rejecting the Hugginses' arguments as frivolous.

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    of 2

    101 F.

    3d 684
    77 A.F.T.R.2d 96-2317

    NOTICE: THIS SUMMARY ORDER MAY NOT BE CITED


    AS PRECEDENTIAL AUTHORITY, BUT MAY BE CALLED
    TO THE ATTENTION OF THE COURT IN A SUBSEQUENT
    STAGE OF THIS CASE, IN A RELATED CASE, OR IN ANY
    CASE FOR PURPOSES OF COLLATERAL ESTOPPEL OR
    RES JUDICATA. SEE SECOND CIRCUIT RULE 0.23.
    David and Donna L. HUGGINS, Petitioners-Appellants,
    v.
    COMMISSIONER OF INTERNAL REVENUE, RespondentAppellee.
    No. 95-4221.

    United States Court of Appeals, Second Circuit.


    May 15, 1996.

    David Huggins, pro se, Rochester, N.Y.


    Donna L. Huggins, pro se, Rochester, N.Y.
    Loretta C. Agrett, U.S. Dep't of Justice, Tax Division, Washington, D.C.
    U.S.T.C.
    AFFIRMED.
    PRESENT: FEINBERG, CABRANES and PARKER, Circuit Judges.

    SUMMARY ORDER
    1

    This cause came on to be heard on the transcript of record from the United
    States Tax Court and was taken on submission.

    ON CONSIDERATION WHEREOF, IT IS HEREBY ORDERED,

    ADJUDGED AND DECREED that the judgment of the United States Tax
    Court is hereby AFFIRMED.
    3

    In 1992 and at the time of trial, petitioners-appellants David and Donna


    Huggins were citizens of the United States and residents of New York. In 1992
    petitioners worked for various businesses and earned income. Instead of filing
    Federal Income Tax Returns 1040 for 1992, they filed Forms 1040NR,
    applicable to non-resident aliens. Petitioners failed to report substantial amounts
    of their income on the 1040NR forms.

    Respondent issued notices of deficiency to petitioners, asserted delinquency


    penalties against them and prepared substitute Federal Income Tax Returns
    1040 for both petitioners for 1992.

    At the trial before the United States Tax Court, petitioners--who, in the Tax
    Court's words, "ma[d]e various tax protestor arguments"--claimed that their
    income was non-taxable. They also argued that the Commissioner had no
    authority to prepare substitute returns and that the notice of deficiency was not
    valid. The court found that petitioners' claims had no merit and entered
    judgment for Respondent.

    Petitioners continue to pursue these and similarly frivolous arguments on


    appeal. For substantially the reasons stated by Judge Swift in his findings
    entered on the record on June 5, 1995, we affirm the judgment of the United
    States Tax Court.

    We have considered all of petitioners' contentions on this appeal and have


    found them to be without merit.

    Accordingly, the judgment of the Tax Court is AFFIRMED.

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