Estate of Temple v. Commissioner
United States Tax Court
The taxpayer's conduct was intimately entwined with the inaccurate and incomplete recording of his business income, and the resulting substantial understatements of income on his 1964, 1965, and 1966 Federal income tax returns. Held, the taxpayer's returns for 1964, 1965, and 1966 were false and fraudulent with the intent to evade taxes, thereby lifting the bar on the assessment and collection of the deficiencies for those years.
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The taxpayer's conduct was intimately entwined with the inaccurate and incomplete recording of his business income, and the resulting substantial understatements of income on his 1964, 1965, and 1966 Federal income tax returns. Held, the taxpayer's returns for 1964, 1965, and 1966 were false and fraudulent with the intent to evade taxes, thereby lifting the bar on the assessment and collection of the deficiencies for those years. Held, further, the additions to tax under sec. 6653(b), I.R.C. 1954, are applicable. Held, further, respondent's determinations of the amount of the deficiencies…
1Opinion of the Court
Bruce, Judge:
Respondent determined deficiencies in Federal income taxes and additions to tax for fraud under section 6653(b), I.R.C. 1954,1 against the taxpayer, Hollis R. Temple, in these consolidated cases2 as follows:
Addition to tax
Calendar year Deficiency sec. 6653(b)
Docket No. 728-72
1964. $25,814.73 $12,907.37
1965. 7,188.13 3,594.07
Docket No. 727-72
1966. 17,152.11 8,576.06
Notices of the deficiencies were mailed to the taxpayer on November 2, 1971, and the petitions herein were filed on January 31, 1972.3 Since the notices of deficiencies were not mailed to the taxpayer within 3 years…
2Cases cited16 opinions
- Stone v. CommissionerUnited States Tax Court · 1971
- Otsuki v. CommissionerUnited States Tax Court · 1969
- Mitchell v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1941
- Condor Merritt v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1962
- Howell v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1949
11 more not listed; retrieve them via the Exa API.
3Cited by132 opinions
- Estate of Pittard v. CommissionerUnited States Tax Court · 1977
- Brountas v. CommissionerUnited States Tax Court · 1979
- Danenberg v. CommissionerUnited States Tax Court · 1979
- Stephen B. Scallen and Chacke Y. Scallen v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1989
- Estate of Arthur Chase Shafer, Deceased, Chase Shafer, Co-Executor, and Resor Shafer, Co-Executor v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1984
127 more not listed; retrieve them via the Exa API.