Leininger v. Commissioner
United States Board of Tax Appeals
RES JUDICATE. - The instant proceedings involve taxes for the years 1924 to 1929, inclusive. A prior judgment of the Supreme Court in Burnet v. Leininger,285 U.S. 136, involved the years 1920 to 1923, inclusive, between the same parties.
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RES JUDICATE. - The instant proceedings involve taxes for the years 1924 to 1929, inclusive. A prior judgment of the Supreme Court in Burnet v. Leininger,285 U.S. 136, involved the years 1920 to 1923, inclusive, between the same parties. Held, the deficiencies for the several taxable years constitute different causes of action, but that the facts and the issue involved in the former proceedings are substantially the same as in the instant proceedings and therefore the judgment of the Supreme Court in the former proceedings is an estoppel against petitioner making the same contentions in these…
1Opinion of the Court
OPINION.
Black :
These proceedings, duly consolidated, are for the redeter-mination of deficiencies in income tax for the calendar years 1924 to 1929, inclusive, in the respective amounts of $2,030.19, $1,617.08, $2,110.92, $990.99, $1,162.69, and $558.01.
Petitioner contends that, under section 218 (a) of the Revenue Acts of 1924 and 1926 and sections 184 and 182 (a) of the Revenue Act of 1928, there should be included in computing his net income for each of the years 1924 to 1929, inclusive, only 25 percent of the net income of a certain partnership operating in Cleveland, Ohio, under the name…
2Cases cited8 opinions
- Cromwell v. County of SacSupreme Court of the United States · 1877
- Southern Pacific Railroad v. United StatesSupreme Court of the United States · 1897
- Tait v. Western Maryland Railway Co.Supreme Court of the United States · 1933
- Russell v. PlaceSupreme Court of the United States · 1877
- Burnet v. LeiningerSupreme Court of the United States · 1932
3 more not listed; retrieve them via the Exa API.
3Cited by10 opinions
- Wobber Bros. v. CommissionerUnited States Board of Tax Appeals · 1934
- Portage Silica Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- Marshall v. CommissionerUnited States Board of Tax Appeals · 1934
- Driscoll v. CommissionerUnited States Tax Court · 1972
- Hartford-Empire Co. v. CommissionerUnited States Board of Tax Appeals · 1940
5 more not listed; retrieve them via the Exa API.