Iverson v. Commissioner
United States Tax Court
Respondent determined deficiencies against petitioners for 1947, 1948, and 1949. The notices of deficiency for 1947 and 1948 were mailed more than 3 but less than 5 years after returns for 1947 and 1948 were filed. Petitioners omitted from their returns for 1947 and 1948 the amounts of credit sales attributable to 4 partnerships from which they derived most of their income for those years.
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Respondent determined deficiencies against petitioners for 1947, 1948, and 1949. The notices of deficiency for 1947 and 1948 were mailed more than 3 but less than 5 years after returns for 1947 and 1948 were filed. Petitioners omitted from their returns for 1947 and 1948 the amounts of credit sales attributable to 4 partnerships from which they derived most of their income for those years. Held, on the facts, each petitioner omitted from his return in each of the years 1947 and 1948 an amount of gross income in excess of 25 per centum of the gross income stated in his return and the 5-year…
1Opinion of the Court
Bruce, Judge:
Respondent determined deficiencies in the income tax of petitioners as follows:
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By amended answers to the petitions filed therein, respondent claimed additional deficiencies as follows:
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With respect to petitioners John and Alvilda Iverson, Docket No. 48053, respondent also determined that there was an overassessment in petitioners’ income tax for the year 1949 in the amount of $8,032.52.
The parties have agreed that no issue is presented for determination by the Court with respect to the deficiency determined against Edward and Mardrid Reite Davison for…
2Cases cited6 opinions
- Switzer v. CommissionerUnited States Tax Court · 1953
- Seltzer v. CommissionerUnited States Tax Court · 1953
- Gillespie Trust v. CommissionerUnited States Tax Court · 1954
- Leas v. CommissionerUnited States Tax Court · 1955
- O'Bryan v. CommissionerCourt of Appeals for the Ninth Circuit · 1945
1 more not listed; retrieve them via the Exa API.
3Cited by19 opinions
- Ezo Products Co. v. CommissionerUnited States Tax Court · 1961
- Drazen v. CommissionerUnited States Tax Court · 1960
- Estate of Iverson v. CommissionerCourt of Appeals for the Eighth Circuit · 1958
- Surtronics, Inc. v. CommissionerUnited States Tax Court · 1985
- Epic Metals v. CommissionerUnited States Tax Court · 1984
14 more not listed; retrieve them via the Exa API.