Hirschman v. Commissioner
United States Tax Court
Prior to March 15, 1944, petitioners, members of a partnership, with intent to evade tax, filed false and fraudulent partnership and individual income tax returns for the taxable year 1943. In these returns they included the costs but not the receipts of partnership sales in the amount of $ 30,909. On November 6, 1944, petitioners learned of the respondent's investigation of the tax returns of a customer to whom a large portion of these sales had been made.
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Prior to March 15, 1944, petitioners, members of a partnership, with intent to evade tax, filed false and fraudulent partnership and individual income tax returns for the taxable year 1943. In these returns they included the costs but not the receipts of partnership sales in the amount of $ 30,909. On November 6, 1944, petitioners learned of the respondent's investigation of the tax returns of a customer to whom a large portion of these sales had been made. On November 9, 1944, petitioners filed amended partnership and individual income tax returns, reporting the $ 30,909 as income for 1943,…
1Opinion of the Court
OPINION.
Akundell, Judge:
The sole question presented herein is whether the respondent was correct in imposing, in respect to the tax of each petitioner for 1943, a 50 per cent addition to tax for fraud under section 293 (b) of the Intemál Revenue Code.
It is undisputed that the original 1943 partnership return of Clair & Hirschman and the individual income tax returns of the petitioners filed in March 1944 failed to include income in the amount of $30,909. The amounts and sources of this income have been shown by the respondent and are not challenged by the petitioners. On November 6,194i,…
2Cases cited1 opinion
- Wilson v. CommissionerUnited States Tax Court · 1946
3Cited by54 opinions
- Bennett v. CommissionerUnited States Tax Court · 1958
- E. J. Benes & Co. v. CommissionerUnited States Tax Court · 1964
- George M. Still, Inc. v. CommissionerUnited States Tax Court · 1953
- Robinson's Dairy, Inc. v. CommissionerUnited States Tax Court · 1961
- Stewart v. CommissionerUnited States Tax Court · 1976
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