Legal Opinion
Giesen v. United States
District Court, W.D. Wisconsin
Decided September 11, 1973No. 71-C-117PublishedCited by 53 opinions
1Opinion of the Court
OPINION and ORDER
JAMES E. DOYLE, District Judge.
This is an action to recover the penalty imposed under 26 U.S.C. (I.R.C.1954) § 6651(a) for failure to file a timely estate tax return. Defendant has moved, and plaintiff has filed a cross-motion, for summary judgment. I find that there is no genuine issue as to the material facts set forth hereinafter under the heading “Facts.”
FACTS'
The plaintiff is the son of decedent, Emma E. Giesen, who died in Superior, Wisconsin, on August 30, 1964. Plaintiff is a physician by profession and has no knowledge of business practices. All of his own business…
2Cases cited17 opinions
- Davis Et Ux. v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1950
- Haywood Lumber & Mining Co. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1950
- Hatfried, Inc. v. Commissioner of Internal Rev.Court of Appeals for the Third Circuit · 1947
- Ferrando v. United StatesCourt of Appeals for the Ninth Circuit · 1957
- In Re Fisk's Estate. Fisk v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1953
12 more not listed; retrieve them via the Exa API.
3Cited by53 opinions
- United States v. Richard L. Kroll, of the Estate of Gertrude O'reilly, DeceasedCourt of Appeals for the Seventh Circuit · 1977
- Estate of Di Palma v. CommissionerUnited States Tax Court · 1978
- Merian Rohrabaugh, Administratrix of the Estate of John T. Lemen, Sr., Deceased v. United StatesCourt of Appeals for the Seventh Circuit · 1979
- Robert W. Boyle, of the Estate of Myra W. Boyle, Deceased, Plaintiff v. United StatesCourt of Appeals for the Seventh Circuit · 1983
- Gudschinsky v. HartillAlaska Supreme Court · 1991
48 more not listed; retrieve them via the Exa API.