Legal Opinion

Marinzulich v. Commissioner

United States Tax Court

Decided November 28, 1958No. Docket No. 64892PublishedCited by 63 opinions

Evidence is reviewed and it is held respondent failed to establish petitioners filed false and fraudulent income tax returns for any of the years involved, with intent to evade taxes, and, consequently, respondent's determinations of deficiencies are barred by the statute of limitations.

1Opinion of the Court

Mulroney, Judge:

Respondent determined deficiencies in income tax and additions thereto for the petitioners as follows:

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The issue is whether petitioners filed false and fraudulent income tax returns for any of the years involved with intent to evade taxes.

FINDINGS OF FACT.

Some of the facts were stipulated and are found accordingly.

John and Mary Marinzulich are husband and wife who live in Tampa, Florida. John Marinzulich, hereinafter sometimes referred to as petitioner, filed his individual income tax return for the year 1942, and John and Mary Marinzulich filed their joint income…

2Cases cited7 opinions

  1. Holland v. United StatesSupreme Court of the United States · 1955
  2. Davis Et Ux. v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1950
  3. Switzer v. CommissionerUnited States Tax Court · 1953
  4. Ferguson v. CommissionerUnited States Tax Court · 1950
  5. Nicholson v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1937

2 more not listed; retrieve them via the Exa API.

3Cited by63 opinions

  1. Estate of Temple v. CommissionerUnited States Tax Court · 1976
  2. Durovic v. CommissionerUnited States Tax Court · 1970
  3. Vannaman v. CommissionerUnited States Tax Court · 1970
  4. C.B.C. Super Markets, Inc. v. CommissionerUnited States Tax Court · 1970
  5. Mazzoni v. CommissionerUnited States Tax Court · 1970

58 more not listed; retrieve them via the Exa API.

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