Legal Opinion
Josef C. Patchen and Aleyne E. Patchen v. Commissioner of Internal Revenue
Court of Appeals for the Fifth Circuit
Decided July 23, 1958No. 16981PublishedCited by 56 opinions
1Opinion of the Court
JOHN R. BROWN, Circuit Judge.
Presented by this appeal from a decision of the Tax Court adverse to all members (and their wives) of a professional consulting engineering partnership is the question whether the Commissioner could require computation of distributable partnership income for the years 1948-1951 on the accrual rather than cash basis as used in all returns since 1946. Additionally, in the case of one such partner, there is the further question whether penalties for failure to file a declaration of estimated tax, Section 294(d) (1) (A), 26 U.S.C.A., and for substantial underestimate…
2Cases cited56 opinions
- Grace M. Powell, of the Estate of O. E. Powell, Deceased v. Ralph C. Granquist, District Director of Internal RevenueCourt of Appeals for the Ninth Circuit · 1958
- Acker v. CommissionerUnited States Tax Court · 1956
- Caldwell v. Commissioner of Internal Revenue. Commissioner of Internal Revenue v. CaldwellCourt of Appeals for the Second Circuit · 1953
- Fuller v. CommissionerUnited States Tax Court · 1953
- Walter H. Kaltreider and Irene C. Kaltreider v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1958
51 more not listed; retrieve them via the Exa API.
3Cited by56 opinions
- Commissioner v. AckerSupreme Court of the United States · 1959
- Heuer v. CommissionerUnited States Tax Court · 1959
- Pigman v. CommissionerUnited States Tax Court · 1958
- Heman v. CommissionerUnited States Tax Court · 1959
- J. D. Abbott and Kathryn Abbott v. Commissioner of Internal Revenue, Carl M. Wolfe and Mary E. Wolfe v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1958
51 more not listed; retrieve them via the Exa API.