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MORGAN v. C.I.R.

No. 85-1396.

807 F.2d 81 (1986)

Philip S. MORGAN, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided December 16, 1986.

Attorney(s) appearing for the Case

Philip S. Morgan, Canton, Ohio, for petitioner-appellant.

Fred T. Goldberg, Jr., I.R.S., Chief Counsel, Michael L. Paup, Glenn L. Archer, Jr., Tax Div., Dept. of Justice, Washington, D.C., Roger M. Olsen, William S. Estabrook, Martha B. Brissette, for respondent-appellee.

Before WELLFORD and MILBURN, Circuit Judges, and DeMASCIO, District Judge.

WELLFORD, Circuit Judge.

This is an appeal from a decision of the Tax Court, T.C. Memo. 1984-384, which held that certain Forms 1040 filed by Morgan, the taxpayer-appellant, did not qualify as federal income tax returns, that attempted elections by Morgan to file joint returns at a later time were ineffective, and that certain penalties and additions to the taxes determined to be due were appropriate because mitigation provisions...

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