Bates v. Commissioner
United States Tax Court
Held: 1. Respondent failed to establish fraud by clear and convincing evidence. Accordingly petitioner is not liable for the additions to tax because of fraud asserted for the years 1945 through 1949, 1951 and 1952. 2. The assessment and collection of the deficiencies determined for the years 1945 through 1949 are barred by the statute of limitations. 3. As petitioner failed to sustain his burden of proof the deficiencies (with some adjustments) determined for the years 1951…
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Held: 1. Respondent failed to establish fraud by clear and convincing evidence. Accordingly petitioner is not liable for the additions to tax because of fraud asserted for the years 1945 through 1949, 1951 and 1952. 2. The assessment and collection of the deficiencies determined for the years 1945 through 1949 are barred by the statute of limitations. 3. As petitioner failed to sustain his burden of proof the deficiencies (with some adjustments) determined for the years 1951 and 1952 are sustained. 4. Petitioner's failure to file declarations of estimated tax for the years 1951 and 1952 was…
1Opinion of the Court
Ralph B. Bates v. Commissioner.
Bates v. Commissioner
Docket Nos. 51979, 51980.
United States Tax Court
T.C. Memo 1956-12; 1956 Tax Ct. Memo LEXIS 284; 15 T.C.M. (CCH) 47; T.C.M. (RIA) 56012;
January 19, 1956
Held: 1. Respondent failed to establish fraud by clear and convincing evidence. Accordingly petitioner is not liable for the additions to tax because of fraud asserted for the years 1945 through 1949, 1951 and 1952.
2. The assessment and collection of the deficiencies determined for the years 1945 through 1949 are barred by the statute of limitations.
3. As petitioner failed to sustain his…
2Cases cited8 opinions
- Halle v. CommissionerUnited States Tax Court · 1946
- Reis v. CommissionerUnited States Tax Court · 1942
- Rogers v. CommissionerUnited States Board of Tax Appeals · 1938
- Bouche v. CommissionerUnited States Tax Court · 1952
- KERBAUCH v. COMMISSIONERUnited States Board of Tax Appeals · 1934
3 more not listed; retrieve them via the Exa API.