Legal Opinion

C.B.C. Super Markets, Inc. v. Commissioner

United States Tax Court

Decided April 28, 1970No. Docket Nos. 4999-67, 5000-67, 5001-67Published

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.

Read the full summary

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

  1. Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
  2. Commissioner v. SunnenSupreme Court of the United States · 1948
  3. Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
  4. Tait v. Western Maryland Railway Co.Supreme Court of the United States · 1933
  5. Commissioner v. SternSupreme Court of the United States · 1958

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

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API