Legal Opinion

Middleton v. Commissioner of Internal Revenue

Court of Appeals for the Fifth Circuit

Decided November 22, 1952No. 13946PublishedCited by 17 opinions

1Opinion of the Court

RUSSELL, Circuit Judge.

The petitioner timely filed his individual income tax returns for the years 1942 through 1947, inclusive, with the Collector of Internal Revenue, Jacksonville, Florida. These returns, with minor exceptions, accurately disclosed petitioner’s income from his restaurant and tavern business and certain rental income, but failed to report any gains received by petitioner from his gambling activities for the years 1942 through 1945, and grossly understated gambling gains realized during the years 1946 and 1947. On October 26, 1948, petitioner filed amended income tax returns…

2Cases cited6 opinions

  1. Mitchell v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1941
  2. Hirschman v. CommissionerUnited States Tax Court · 1949
  3. Eck v. CommissionerUnited States Tax Court · 1951
  4. Wilson v. CommissionerUnited States Tax Court · 1946
  5. McLaughlin v. CommissionerUnited States Board of Tax Appeals · 1933

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

3Cited by17 opinions

  1. 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
  2. Robinson's Dairy, Inc. v. CommissionerUnited States Tax Court · 1961
  3. Joseph N. Romm and Helen K. Romm, His Wife v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1957
  4. Newsom v. CommissionerUnited States Tax Court · 1954
  5. Frank C. And Mary Papa v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1972

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

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