Legal Opinion
Madyo A. Poletti and Marian Poletti v. Commissioner of Internal Revenue
Court of Appeals for the Eighth Circuit
Decided October 19, 1965No. 17968PublishedCited by 22 opinions
1Opinion of the Court
MATTHES, Circuit Judge.
For the second time this case is before us on a petition to review the Tax Court’s determination of the income tax liability of petitioners for the years 1955, 1956 and 1957. The key issue in the first appeal was whether the Tax Court erred in failing to apply the Cohan rule 1 to a portion of the expenditures made by petitioners. We decided that issue in favor of petitioners and remanded, “for further proceedings consistent with this decision.” Poletti v. C. I. R., 330 F.2d 818, 824 (1964). The purport and effect of that opinion is one of the issues in this proceeding.
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2Cases cited11 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Briggs v. Pennsylvania RailroadSupreme Court of the United States · 1948
- Thornton v. CarterCourt of Appeals for the Eighth Circuit · 1940
- Guettel v. United StatesCourt of Appeals for the Eighth Circuit · 1938
- Roth v. HyerCourt of Appeals for the Fifth Circuit · 1944
6 more not listed; retrieve them via the Exa API.
3Cited by22 opinions
- Gunther Graefenhain and Philip Miller, Cross-Appellees v. Pabst Brewing Company, Cross-AppellantCourt of Appeals for the Seventh Circuit · 1989
- Bernard Litman v. Massachusetts Mutual Life Insurance CompanyCourt of Appeals for the Eleventh Circuit · 1987
- Republican Party of Minnesota v. WhiteCourt of Appeals for the Eighth Circuit · 2005
- Charles H. Bethea v. Levi Strauss and CompanyCourt of Appeals for the Eighth Circuit · 1990
- United States v. Perlie Donald WorkmanCourt of Appeals for the Fourth Circuit · 1980
17 more not listed; retrieve them via the Exa API.