Legal Opinion
Sowards v. Comm'r
United States Tax Court
Decided June 19, 2003No. 10025-99; No. 11144-00UnpublishedCited by 4 opinions
1Opinion of the Court
RAY W. AND MARILYN S. SOWARDS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Sowards v. Comm'r
No. 10025-99; No. 11144-00
United States Tax Court
T.C. Memo 2003-180; 2003 Tax Ct. Memo LEXIS 180; 85 T.C.M. (CCH) 1517; IA TM 55195;
June 19, 2003, Filed
Court held that petitioner Ray Sowards omitted significant income from petitioners' 1995, 1996, and 1997 returns and that resulting underpayments for 1996 and 1997, as determined in notice of deficiency, were due to fraud. Petitioners were not entitled to deductions that respondent disallowed and negligence penalties determined by…
2Cases cited52 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Holland v. United StatesSupreme Court of the United States · 1955
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Freytag v. CommissionerSupreme Court of the United States · 1991
- HIGBEE v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001
47 more not listed; retrieve them via the Exa API.
3Cited by4 opinions
- Richardson v. Comm'rUnited States Tax Court · 2006
- HAWKINS v. COMMISSIONERUnited States Tax Court · 2003
- Reinhard v. Comm'rUnited States Tax Court · 2015
- William M. Hawkins and Laura C. Hawkins v. CommissionerUnited States Tax Court · 2003