Legal Opinion

Estate of Hill v. Commissioner

United States Tax Court

Decided March 21, 1973No. Docket Nos. 3076-70, 3077-70PublishedCited by 40 opinions

1. Held, petitioners' motion to suppress evidence upon a claim of an illegal search and seizure is denied because petitioners' decedent voluntarily permitted respondent's agents to obtain his records from his bookkeeper and accountant. 2. Petitioners' decedent omitted amounts of professional gross receipts ranging from $ 2,280.52 to $ 6,000 for 5 consecutive years. Held, part of the deficiency in each year was due to fraud with intent to evade taxes.

1Opinion of the Court

IrwiN, Judge:

Respondent determined the following deficiencies and additions to tax against petitioners for the taxable years 1956 through 1960:

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Respondent has conceded that no part of any underpayment for the years 1959 and 1960 in which joint returns were filed was due to the fraud of the surviving wife, Edith B. Hill. The remaining issues to be decided are:(1) Whether petitioner’s motion to suppress evidence based upon a claim that respondent obtained certain records and documents through an illegal search and seizure should be granted;(2) Whether any part of the deficiencies…

2Cases cited12 opinions

  1. Amos v. CommissionerUnited States Tax Court · 1964
  2. Lewis Thurston Anderson and Clyde Velma Anderson, Lewis Thurston Anderson v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1957
  3. John W. Amos v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1965
  4. Harper v. CommissionerUnited States Tax Court · 1970
  5. George Schwarzkopf v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1957

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

3Cited by40 opinions

  1. McGee v. CommissionerUnited States Tax Court · 1973
  2. Furst v. United StatesUnited States Court of Claims · 1982
  3. Grant v. CommissionerUnited States Tax Court · 1985
  4. Brod v. CommissionerUnited States Tax Court · 1976
  5. Slawek v. CommissionerUnited States Tax Court · 1987

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

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