Legal Opinion

Sullivan v. Commissioner

United States Tax Court

Decided November 21, 1956No. Docket Nos. 39977, 39979PublishedCited by 36 opinions

1. Petitioner Dorothy Sullivan (formerly Dorothy Douglas) was married to Jack Douglas during the years 1946 to December 5, 1949, inclusive.

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1. Petitioner Dorothy Sullivan (formerly Dorothy Douglas) was married to Jack Douglas during the years 1946 to December 5, 1949, inclusive. She separated from him in April 1946, and remained so until the couple was divorced in December 1949. Purported joint returns were filed for the taxable years 1946, 1947, and 1948. These returns for 1946 and 1948 were not signed by Dorothy, she knew nothing about their contents or filing, and had no intention to file joint returns for those years. The return for 1947 was signed by Dorothy in blank. She knew it was to be filled in by Jack and that he…

1Opinion of the Court

OPINION.

Black , Judge:

Issues in Docket No. 39977.

In this docket number the petitioners are Jack Douglas and Dorothy Sullivan (formerly Dorothy Douglas). Jack did not appear at the hearing, either in person or by counsel. Respondent's counsel filed at the hearing a stipulation of settlement, so far as Jack was concerned, signed by Jack’s counsel and respondent’s counsel. That stipulation of settlement is incorporated in our Findings of Fact and will be given effect in a decision under Ride 50 as to Jack’s tax liability for the 3 years, 1946, 1947, and 1948. Jack is not before us as a…

2Cases cited9 opinions

  1. Howell v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1949
  2. Howell v. CommissionerUnited States Tax Court · 1948
  3. SoRelle v. CommissionerUnited States Tax Court · 1954
  4. Heim v. CommissionerUnited States Tax Court · 1956
  5. Eccles v. CommissionerUnited States Tax Court · 1953

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

3Cited by36 opinions

  1. Rodney v. Comm'rUnited States Tax Court · 1969
  2. Estate of Campbell v. CommissionerUnited States Tax Court · 1971
  3. Davenport v. CommissionerUnited States Tax Court · 1967
  4. Hennen v. CommissionerUnited States Tax Court · 1961
  5. Kirk v. United States, Department of Internal Revenue (In Re Kirk)United States Bankruptcy Court, M.D. Florida · 1989

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

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