Legal Opinion
Charles Dodge Christine Y. Roberts v. Commissioner of Internal Revenue
Court of Appeals for the Eighth Circuit
Decided January 20, 1993No. 92-1372PublishedCited by 44 opinions
1Opinion of the Court
BEAM, Circuit Judge.
Charles Dodge and Christine Roberts jointly appeal a tax court judgment 1 holding them liable for back taxes and penalties. For reversal, appellants argue: 1) that the IRS assessment against them was a naked assessment not entitled to the presumption of correctness normally afforded IRS assessments; 2) that they identified a large percentage of the bank deposits as nontaxable, and therefore the burden of proof shifted to the IRS to show a taxable source for the disputed bank deposits — a burden the IRS failed to meet; 3) that the IRS failed to prove that Dodge’s insurance…
2Cases cited10 opinions
- Anderson v. City of Bessemer CitySupreme Court of the United States · 1985
- Ramon Portillo and Dolores Portillo v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1991
- United States v. StonehillCourt of Appeals for the Ninth Circuit · 1983
- Mary Ruark v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1971
- Audrey L. Zeeman, Individually and as of the Estate of Leon S. Lees, Jr. v. United StatesCourt of Appeals for the Second Circuit · 1968
5 more not listed; retrieve them via the Exa API.
3Cited by44 opinions
- United States v. Fior D'Italia, Inc.Supreme Court of the United States · 2002
- Donald R. Ferguson v. United States v. Richard Musal, Third Party Nicholas P. Miller, Third PartyCourt of Appeals for the Third Circuit · 2007
- James A. Pittman v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1996
- Anuforo v. CommissionerCourt of Appeals for the Eighth Circuit · 2010
- Joseph P. Caulfield v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1994
39 more not listed; retrieve them via the Exa API.