Legal Opinion
B. B. Carter and Mrs. Tommie v. Carter v. Ellis Campbell, Jr., Director of Internal Revenue
Court of Appeals for the Fifth Circuit
Decided March 10, 1959No. 17443PublishedCited by 132 opinions
1Opinion of the Court
JOHN R. BROWN, Circuit Judge.
This appeal turns on the burden of proof in a taxpayer’s suit to recover civil fraud income tax penalties. Intertwined are those naturally related to that question — was the burden properly interpreted and applied by the District Court, and, if so, did the evidence justify the finding and judgment adverse to the taxpayer. In the disposition we make of the ease at this stage, the situation can be briefly summarized.
Carter, the appellant-Taxpayer, in his brief correctly describes this as a civil sequel1 to his last visit here. Carter v. United States, 5 Cir., 1955,…
2Cases cited28 opinions
- Helvering v. TaylorSupreme Court of the United States · 1935
- Stone v. WhiteSupreme Court of the United States · 1937
- Mitchell v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1941
- Reinecke v. SpaldingSupreme Court of the United States · 1930
- William J. Drieborg and Laura D. Drieborg v. Commissioner of Internal Revenue, William J. Drieborg v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1955
23 more not listed; retrieve them via the Exa API.
3Cited by132 opinions
- Beaver v. CommissionerUnited States Tax Court · 1970
- Bolen Webb and Cornelia Webb v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1968
- Vincent Cefalu and Frances P. Cefalu v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1960
- Sidney Kreps v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1965
- Durovic v. CommissionerUnited States Tax Court · 1970
127 more not listed; retrieve them via the Exa API.