Flanagan v. Commissioner
United States Tax Court
J was convicted under sec. 7201, I.R.C. 1954, of filing false and fraudulent returns with the intent to evade a large part of his Federal income taxes for 1963 and 1964. When this case was called for trial, there was no appearance by, or on behalf of, J. Held: (1) By relying on the doctrine of collateral estoppel, the Commissioner has satisfied his burden of proving that J's returns for such years were fraudulent with intent to evade tax so that the statute of limitations…
Read the full summary
J was convicted under sec. 7201, I.R.C. 1954, of filing false and fraudulent returns with the intent to evade a large part of his Federal income taxes for 1963 and 1964. When this case was called for trial, there was no appearance by, or on behalf of, J. Held: (1) By relying on the doctrine of collateral estoppel, the Commissioner has satisfied his burden of proving that J's returns for such years were fraudulent with intent to evade tax so that the statute of limitations has not run with respect to such years ( sec. 6501(c)(1), I.R.C. 1954), and the Commissioner's motion for partial summary…
1Opinion of the Court
JOHN WEBSTER FLANAGAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
BETTY FLANAGAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Flanagan v. Commissioner
Docket Nos. 1303-73, 1449-73.
United States Tax Court
T.C. Memo 1976-116; 1976 Tax Ct. Memo LEXIS 288; 35 T.C.M. (CCH) 528; T.C.M. (RIA) 760116;
April 15, 1976, Filed
J was convicted under sec. 7201, I.R.C. 1954, of filing false and fraudulent returns with the intent to evade a large part of his Federal income taxes for 1963 and 1964. When this case was called for trial, there was no appearance by, or on behalf of, J.
Held…
2Cases cited10 opinions
- Haldane M. Plunkett v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1972
- Amos v. CommissionerUnited States Tax Court · 1964
- John W. Amos v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1965
- Tomlinson v. LefkowitzCourt of Appeals for the Fifth Circuit · 1964
- Arctic Ice Cream Co. v. CommissionerUnited States Tax Court · 1964
5 more not listed; retrieve them via the Exa API.