Legal Opinion

John Factor v. Commissioner of Internal Revenue

Court of Appeals for the Ninth Circuit

Decided July 27, 1960No. 16326PublishedCited by 94 opinions

1Opinion of the Court

YANKWICH, District Judge.

Before us is a petition filed October 22, 1958, to review 1 the decision of the Tax Court entered July 24, 1958, relating to federal income taxes for the taxable years 1935 and 1936.

On August 9, 1946, the Commissioner of Internal Revenue mailed to the taxpayer notice of deficiencies in the amount of $38,315.03 for the year 1935 and $134,-912.23 for the year 1936, with an added fraud penalty of fifty per cent for each year.

On November 4, 1946, i. e., within the ninety day period, the taxpayer filed a petition with the Tax Court for a redetermination of the…

2Cases cited114 opinions

  1. Conley v. GibsonSupreme Court of the United States · 1957
  2. New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
  3. Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
  4. Gregory v. HelveringSupreme Court of the United States · 1935
  5. Commissioner v. SunnenSupreme Court of the United States · 1948

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

3Cited by94 opinions

  1. Robert W. Bradford v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1986
  2. Professional Services v. CommissionerUnited States Tax Court · 1982
  3. Shomaker v. CommissionerUnited States Tax Court · 1962
  4. The Estate of Grace E. Lang, Deceased. Richard E. Lang v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1980
  5. Mary Ruark v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1971

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

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