Legal Opinion

Wiseley v. Commissioner of Internal Revenue

Court of Appeals for the Sixth Circuit

Decided November 24, 1950No. 11146PublishedCited by 51 opinions

1Opinion of the Court

HICKS, Chief Judge.

Petitioner, Frank M. Wiseley, seeks a review of the decision of the Tax Court affirming the action of the Commissioner of Internal Revenue in assessing against him a deficiency in income taxes for the calendar year 1942 in the sum of $4,203.94 and a penalty of $2,101.97; and in assessing penalties against him of $6,149.20, $8,373.25 and $7,110.88 for the years 1943, 1944 and 1945.

There is substantial evidence to support the findings touching the deficiency for the year 1942 and the decision of the Tax Court in relation thereto is accordingly affirmed.

We are not in accord…

2Cases cited3 opinions

  1. Mitchell v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1941
  2. Rogers v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1940
  3. Duffin v. LucasCourt of Appeals for the Sixth Circuit · 1932

3Cited by51 opinions

  1. Grace M. Powell, of the Estate of O. E. Powell, Deceased v. Ralph C. Granquist, District Director of Internal RevenueCourt of Appeals for the Ninth Circuit · 1958
  2. Habersham-Bey v. CommissionerUnited States Tax Court · 1982
  3. William J. Drieborg and Laura D. Drieborg v. Commissioner of Internal Revenue, William J. Drieborg v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1955
  4. Gene O. Clark and Faye Clark v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1959
  5. Stein v. CommissionerUnited States Tax Court · 1956

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