Legal Opinion

Clifford F. Mack and Helen L. Mack v. Commissioner of Internal Revenue

Court of Appeals for the Sixth Circuit

Decided July 20, 1970No. 20098_1PublishedCited by 40 opinions

1Opinion of the Court

O’SULLIVAN, Senior Circuit Judge.

This cause is before the Court on the appeal of Clifford F. Mack and his wife from a judgment of the Tax Court which, for the tax year of 1964, reduced his claim of wagering losses from an asserted $27,200 to $14,000. As provided in 26 U.S.C. § 165(d), a taxpayer may claim deduction for wagering losses “only to the extent of the gains from such transactions.” Appellants also challenge the propriety of a 5% negligence penalty imposed upon the amount of the appellants’ underpayment of income tax for the year 1964. This is provided by 26 U.S.C. § 6653(a). The…

2Cases cited6 opinions

  1. Commissioner v. DubersteinSupreme Court of the United States · 1960
  2. Carlos and Jacqueline Marcello v. Commissioner of Internal Revenue, Joseph, Jr. And Anastasia Marcello v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1967
  3. Burnet v. HoustonSupreme Court of the United States · 1931
  4. Daniel F. Donovan v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1966
  5. Peter J. And Penny v. Marcello v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1967

1 more not listed; retrieve them via the Exa API.

3Cited by40 opinions

  1. Preben Norgaard Sandra C. Norgaard v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1991
  2. S. S. Ballin Agency, Inc. v. CommissionerCourt of Appeals for the Third Circuit · 1971
  3. Estate of Mercure v. CommissionerCourt of Appeals for the Sixth Circuit · 1971
  4. Rios v. Comm'rUnited States Tax Court · 2012
  5. Sang J. Park v. CommissionerUnited States Tax Court · 2011

35 more not listed; retrieve them via the Exa API.

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