Legal Opinion

Frank J. Hradesky v. Commissioner of Internal Revenue

Court of Appeals for the Fifth Circuit

Decided October 15, 1976No. 76-2393PublishedCited by 414 opinions

1Per curiam

Hradesky (Taxpayer) appeals from a ruling by the Tax Court 1 upholding the Commissioner’s deficiency determination for the 1966 and 1967 tax years. With the exception of Taxpayer’s contentions regarding irrevocable payment of real estate taxes to a third person, non-taxing authority, this Court finds all other asserted errors to be without merit. 2

Addressing Taxpayer’s remaining and only serious point of error, this Court does not undertake consideration of and does not pass on the question of whether a deduction for real estate taxes under 26 U.S.C.A. § 164(a)(1) must be allowed a cash basis…

2Cases cited14 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Phillips v. CommissionerSupreme Court of the United States · 1931
  3. Hradesky v. CommissionerUnited States Tax Court · 1975
  4. Federal Communications Commission v. WJR, Goodwill Station, Inc.Supreme Court of the United States · 1949
  5. W. F. Chaney v. City of Galveston, Earl J. Smith & Co., Inc. v. City of GalvestonCourt of Appeals for the Fifth Circuit · 1966

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3Cited by414 opinions

  1. HIGBEE v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001
  2. Capek v. CommissionerUnited States Tax Court · 1986
  3. Norman B. Tapper and Eileen Tapper v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1985
  4. Lofstrom v. Comm'rUnited States Tax Court · 2005
  5. Campbell v. CommissionerUnited States Tax Court · 2010

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