Otsuki v. Commissioner
United States Tax Court
1. Held, that some part of the underpayment determined for each of the years involved is due to fraud with intent to evade tax on the part of petitioner wife within the purview of sec. 6653(b), I.R.C. 1954. 2. Held, further, that petitioners are jointly and severally liable for the determined income tax deficiencies, including the addition to tax for fraud, under sec. 6013(d)(3), I.R.C. 1954.
1Opinion of the Court
Withet, Judge:
Respondent determined deficiencies in income tax and additions to tax for fraud under section 6653 (b) ,1 I.R.C. 1954, as follows:
Year Deficiency Additions to tax sec.6653 (a) [2]
1959_ $2, 707. 71 $1, 353. 85
1960_ 3, 260. 53 1, 630. 26
1961___ 4, 988. 95 2, 494. 47
1962_ 5, 336. 49 2, 668. 24
1963_ 1, 754. 67 877. 33
The parties have stipulated all of the material facts pertaining to the unreported income involved herein and after the opening statement, counsel for petitioners agreed that the deficiencies were correct.
The principal issues presented for our consideration are:(1)…
2Cases cited34 opinions
- Holland v. United StatesSupreme Court of the United States · 1955
- Helvering v. MitchellSupreme Court of the United States · 1938
- United States v. JohnsonSupreme Court of the United States · 1943
- Condor Merritt v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1962
- Amos v. CommissionerUnited States Tax Court · 1964
29 more not listed; retrieve them via the Exa API.
3Cited by620 opinions
- Rowlee v. CommissionerUnited States Tax Court · 1983
- Stone v. CommissionerUnited States Tax Court · 1971
- Grosshandler v. CommissionerUnited States Tax Court · 1980
- Petzoldt v. CommissionerUnited States Tax Court · 1989
- Niedringhaus v. CommissionerUnited States Tax Court · 1992
615 more not listed; retrieve them via the Exa API.