Legal Opinion

E. E. R. Shapiro and Rubye Shapiro v. Commissioner of Internal Revenue

Court of Appeals for the Ninth Circuit

Decided October 13, 1961No. 17136_1PublishedCited by 13 opinions

1Opinion of the Court

MERRILL, Circuit Judge.

Taxpayers, husband and wife, have petitioned for review of a tax court decision sustaining deficiencies in income for the years 1945 to 1948, plus penalties. Since the amounts in dispute result from business dealings of the husband, we shall, in discussing the problem, refer to him as though he were the sole taxpayer.

During the years in question, taxpayer was engaged in business in San Francisco as a dealer in used automobiles. The financing of time sales was accomplished by arrangement with Pacific Finance Company, by which that company accepted taxpayer’s conditional…

2Cases cited3 opinions

  1. Commissioner v. HansenSupreme Court of the United States · 1959
  2. Arthur v. Morgan and Dorothy O. Morgan v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1960
  3. Vance L. Wiley v. Commissioner of Internal Revenue, Frank D. Wiley v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1959

3Cited by13 opinions

  1. Johnson v. CommissionerUnited States Tax Court · 1997
  2. Gunderson Bros. Engineering Corp. v. CommissionerUnited States Tax Court · 1964
  3. Federated Dep't Stores, Inc. v. CommissionerUnited States Tax Court · 1968
  4. A. v. Worley v. United StatesCourt of Appeals for the Ninth Circuit · 1965
  5. Resale Mobile Homes, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1992

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