Legal Opinion

Downs v. COMMISSIONER OF INTERNAL REVENUE.

Court of Appeals for the Ninth Circuit

Decided January 27, 1948No. 11578, 11593PublishedCited by 61 opinions

1Opinion of the Court

STEPHENS, Circuit Judge.

The cases of Downs v. Commissioner, No. 11,578, and Hoofnel v. Commissioner, No. 11,593, here from the Tax Court on review, call for decision, mainly, upon the same basic principles. By general agreement they were tried together to the Tax Court, and were argued together here, although the cases are separately briefed. We shall dispose of the two cases in one opinion.

The Commissioner of Internal Revenue found Downs delinquent in his income taxes, due for the year 1943, and Hoofnel delinquent in his income taxes for the years 1942 and 1943. The Tax Court upheld the…

2Cases cited5 opinions

  1. In Re Revocation of Ancillary Letters Testamentary of the Estate of NewcombNew York Court of Appeals · 1908
  2. Swenson v. ThomasCourt of Appeals for the Fifth Circuit · 1947
  3. Commissioner of Internal Revenue v. SwentCourt of Appeals for the Fourth Circuit · 1946
  4. Commissioner of Internal Revenue v. Fiske's EstateCourt of Appeals for the Seventh Circuit · 1942
  5. Carstairs v. United StatesDistrict Court, E.D. Pennsylvania · 1936

3Cited by61 opinions

  1. Glenn Weible and Patricia Weible v. United StatesCourt of Appeals for the Ninth Circuit · 1957
  2. Howard J. Sochurek v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1962
  3. Sanders v. CommissionerUnited States Tax Court · 1954
  4. Bebb v. CommissionerUnited States Tax Court · 1961
  5. Nelson v. CommissionerUnited States Tax Court · 1958

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