Legal Opinion

Patton v. Commissioner of Internal Revenue

Court of Appeals for the Sixth Circuit

Decided April 19, 1948No. 10534PublishedCited by 24 opinions

1Opinion of the Court

HICKS, Circuit Judge.

Respondent found a deficiency in the income and victory taxes for 1943 of petitioner, James F. Patton, in the sum of $16,561.12, and of petitioner, Vincent Patton, in the sum of $16,361.80. The cases were consolidated for hearing before the Tax Court and here. The Tax Court confirmed the deficiency assessments and we are asked to review its decision.

The cases arose under Sec. 23, Internal Revenue Code, 26 U.S.C.AJnt.Rev.Code, § 23, which in so far as is applicable, is printed in the margin.1

During the calendar year 1943 petitioners were partners doing a general jobbing…

2Cases cited9 opinions

  1. Hormel v. HelveringSupreme Court of the United States · 1941
  2. Botany Worsted Mills v. United StatesSupreme Court of the United States · 1929
  3. Helvering v. Tex-Penn Oil Co.Supreme Court of the United States · 1937
  4. Wilmington Trust Co. v. HelveringSupreme Court of the United States · 1942
  5. Tracy v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1931

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

3Cited by24 opinions

  1. Clínica Dr. Mario Juliá, Inc. v. Secretario de HaciendaSupreme Court of Puerto Rico · 1954
  2. James D. Kennedy, Jr. And Dorothy H. Kennedy, and Cherokee Warehouses, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1982
  3. Constance M. Bishop v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1965
  4. Laure v. CommissionerUnited States Tax Court · 1978
  5. Jones Brothers Bakery, Inc. v. The United StatesUnited States Court of Claims · 1969

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