Legal Opinion

Horace R. Walter Donna L. Walter v. United States

Court of Appeals for the Eighth Circuit

Decided July 8, 1998No. 96-3828PublishedCited by 8 opinions

1Opinion of the Court

LOKEN, Circuit Judge.

Horace and Donna Walter farm and feed cattle in rural Clark County, South Dakota. By 1985 and 1986, the tax years in question, they were feeding and selling over 8,000 cattle per year and farming about 2,000 acres. In their joint federal income tax returns for those years, the Walters reported taxable income of $195,353 in 1985 and $204,-513 in 1986. In 1988, the Commissioner of Internal Revenue audited the returns, increasing the Walters’ taxable income to $393,817 in 1985 and $529,159 in 1986, and assessing negligence and substantial understatement penalties. See 26…

2Cases cited10 opinions

  1. Thor Power Tool Co. v. CommissionerSupreme Court of the United States · 1979
  2. Avery v. CommissionerSupreme Court of the United States · 1934
  3. Loose v. United StatesCourt of Appeals for the Eighth Circuit · 1934
  4. Kahler v. Comm'rUnited States Tax Court · 1952
  5. Joseph P. Caulfield v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1994

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3Cited by8 opinions

  1. Shiner v. TurnoyDistrict Court, N.D. Illinois · 2014
  2. In Re Worldcom, Inc.United States Bankruptcy Court, S.D. New York · 2007
  3. Diana T. Visco v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 2002
  4. Ormsby v. Department of RevenueOregon Tax Court · 2004
  5. United States v. Six Negotiable Checks in Various Denominations Totaling One Hundred Ninety One Thousand Six Hundred Seventy One Dollars & Sixty Nine CentsDistrict Court, E.D. Michigan · 2005

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