Wilson v. Commissioner
United States Tax Court
Petitioner concedes that a part of the income tax deficiency determined for the taxable years 1936 and 1940, in controversy, was due to fraud with intent to evade the tax. Held, the 50 per cent penalty prescribed by section 293 (b), I. R. C., is to be computed on the total deficiency, which is the difference between the amount of the tax liability and the amount disclosed on the return.
1Opinion of the Court
OPINION.
Leech, Judge:
The above entitled proceeding involves deficiencies in income tax, and fraud penalties, as follows:
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The only issue in controversy relates to the proper method of computing the fraud penalty in the taxable years 1936 and 1940. A stipulation of facts was filed, and certain waivers, and concessions were made at the trial. The facts as stipulated are so found. Those material here may be summarized as follows:
Petitioner, an individual, filed his income tax returns for the periods involved with the collector of internal revenue for the twenty-third district of…
2Cases cited1 opinion
- Helvering v. KehoeSupreme Court of the United States · 1940
3Cited by40 opinions
- Breman v. CommissionerUnited States Tax Court · 1976
- Bennett v. CommissionerUnited States Tax Court · 1958
- George M. Still, Inc. v. CommissionerUnited States Tax Court · 1953
- William Levinson and William Levinson, Assignee of F.M.P. Corporation, Formerly Known as Fairmount Motor Products Co., Inc. v. United StatesCourt of Appeals for the Third Circuit · 1974
- Robinson's Dairy, Inc. v. CommissionerUnited States Tax Court · 1961
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