Legal Opinion

Manuel Cebollero v. Commissioner of Internal Revenue

Court of Appeals for the Fourth Circuit

Decided June 19, 1992No. 91-1153PublishedCited by 39 opinions

1Opinion of the Court

OPINION

RAMSEY, Senior District Judge:

Manuel Cebollero, the taxpayer, appeals from the tax court’s decision sustaining the Commissioner’s determination of income tax deficiencies for tax years 1982-1984. We now affirm.

I

The facts are set forth in detail in the opinion below, Cebollero v. Commissioner, 60 T.C.M. (CCH) 1379, 1990 WL 192757 (1990), and we repeat them only to the extent necessary to resolve the issues raised by this appeal.

Appellant and his wife owned a beer and wine store (“Belby”) in Montgomery County, Maryland, which they operated as general partners during the period at issue.…

2Cases cited25 opinions

  1. Anderson v. City of Bessemer CitySupreme Court of the United States · 1985
  2. Welch v. HelveringSupreme Court of the United States · 1933
  3. United States v. JanisSupreme Court of the United States · 1976
  4. Helvering v. TaylorSupreme Court of the United States · 1935
  5. Bolen Webb and Cornelia Webb v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1968

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3Cited by39 opinions

  1. In Re Landbank Equity Corporation, a Virginia Corporation, Debtor. Internal Revenue Service v. Laurence H. Levy, Trustee, Debera F. ConlonCourt of Appeals for the Fourth Circuit · 1992
  2. Jonathan B. Geftman v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1998
  3. Dye v. United StatesCourt of Appeals for the Tenth Circuit · 1997
  4. Boch v. United States (In Re Boch)United States Bankruptcy Court, M.D. Pennsylvania · 1993
  5. Maryam Balbed v. Eden Park Guest House, LLCCourt of Appeals for the Fourth Circuit · 2018

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