Legal Opinion

I. E. Doggett v. Commissioner of Internal Revenue

Court of Appeals for the Fourth Circuit

Decided March 8, 1960No. 7915PublishedCited by 17 opinions

1Opinion of the Court

HAYNSWORTH, Circuit Judge.

The principal question arises out of the imposition of fraud penalties on income tax deficiencies for the years 1942-1946. Though the taxpayer admits the presence of false entries in his books during the years 1942-1945 and unrecorded and unreported receipts during 1946, he earnestly attributes all fault to his bookkeeper whom he charges with embezzlement and perjury. The bookkeeper, as earnestly, protests his innocence of those crimes, but admits he falsified the records, under taxpayer’s instructions, for the purpose of concealing income.

The Tax Court accepted the…

2Cases cited3 opinions

  1. Lillian Kilpatrick v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. Lillian KilpatrickCourt of Appeals for the Fifth Circuit · 1955
  2. Masters v. CommissionerCourt of Appeals for the Third Circuit · 1957
  3. Citizens Nat. Trust & Savings Bank of Los Angeles v. WelchCourt of Appeals for the Ninth Circuit · 1941

3Cited by17 opinions

  1. Hicks Co. v. CommissionerUnited States Tax Court · 1971
  2. Kniffen v. CommissionerUnited States Tax Court · 1962
  3. B & L FARMS CO. v. United StatesDistrict Court, S.D. Florida · 1965
  4. Joseph F. Kisting v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1962
  5. Royal Oak Apartments, Inc. v. CommissionerUnited States Tax Court · 1964

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