C.B.C. Super Markets, Inc. v. Commissioner
United States Tax Court
Held: 1. Deficiencies of the individual petitioners and corporate petitioner redetermined. 2. Petitioner Frank C. Cicio's conviction under sec. 7201, I.R.C. 1954, for filing false and fraudulent returns for 1958, 1959, and 1960 collaterally estops him from denying that a part of the underpayments for those years was due to fraud.
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Held: 1. Deficiencies of the individual petitioners and corporate petitioner redetermined. 2. Petitioner Frank C. Cicio's conviction under sec. 7201, I.R.C. 1954, for filing false and fraudulent returns for 1958, 1959, and 1960 collaterally estops him from denying that a part of the underpayments for those years was due to fraud. His conviction does not collaterally estop his wife from so denying, Henry M. Rodney, 53 T.C. 287 (1969), followed. 3. Petitioner Frank C. Cicio's conviction under sec. 7201, I.R.C. 1954, for filing and causing the corporation in which he was the principal…
1Opinion of the Court
C.B.C. Super Markets, Inc., Transferor, Frank C. Cicio, Transferee, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent
C.B.C. Super Markets, Inc. v. Commissioner
Docket Nos. 4999-67, 5000-67, 5001-67
United States Tax Court
54 T.C. 882; 1970 U.S. Tax Ct. LEXIS 153;
April 28, 1970, Filed
Decision will be entered for petitioner in docket No. 4999-67.
Decisions will be entered under Rule 50 in docket Nos. 5000-67 and 5001-67.
Held: 1. Deficiencies of the individual petitioners and corporate petitioner redetermined.
2. Petitioner Frank C. Cicio's conviction under sec. 7201, I.R.C. 1954,…
Also in this document: Dissent.
2Cases cited54 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- Tait v. Western Maryland Railway Co.Supreme Court of the United States · 1933
- Commissioner v. SternSupreme Court of the United States · 1958
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