Legal Opinion
Michael A. Schaffer and Jennifer Schaffer v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided December 16, 1985No. 1094, Docket 83-4100PublishedCited by 29 opinions
1Opinion of the Court
JON 0. NEWMAN, Circuit Judge.
This appeal poses vexing questions concerning the income tax liability of an individual who participates with others in income-generating activity. The questions arise in an appeal by Michael A. Schaffer and his wife 1 from a judgment of the Tax Court (Irene F. Scott, Judge) determining a deficiency in their 1969 federal income tax of $159,807.69 and assessing against Schaf-fer a fraud penalty of $79,903.85. See Mandina v. C.I.R., 43 T.C.M. (CCH) 359 (1982). For reasons that follow, we affirm only in part and remand for entry of a modified judgment.
The Legal…
2Cases cited31 opinions
- United States v. United States Gypsum Co.Supreme Court of the United States · 1948
- Welch v. HelveringSupreme Court of the United States · 1933
- Pinkerton v. United StatesSupreme Court of the United States · 1946
- United States v. JanisSupreme Court of the United States · 1976
- Bolen Webb and Cornelia Webb v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1968
26 more not listed; retrieve them via the Exa API.
3Cited by29 opinions
- Robert Demartino, Appellant-Cross-Appellee v. Commissioner of Internal Revenue, Appellee-Cross-AppellantCourt of Appeals for the Second Circuit · 1988
- Vallone v. CommissionerUnited States Tax Court · 1987
- Board of Trustees of the Western Conference of Teamsters Pension Trust Fund v. H.F. Johnson, Inc.Court of Appeals for the Ninth Circuit · 1987
- Merkel v. CommissionerUnited States Tax Court · 1997
- Andrew Crispo Gallery, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1994
24 more not listed; retrieve them via the Exa API.