Legal Opinion

Tomlinson v. Lefkowitz

Court of Appeals for the Fifth Circuit

Decided July 13, 1964No. 21094PublishedCited by 134 opinions

1Opinion of the Court

TUTTLE, Chief Judge.

This case is before us on cross-appeals of taxpayers Sidney and Rose Lefkowitz and the District Director of Internal Revenue to the judgment of the trial court in taxpayers’ refund suit. At issue are certain penalties assessed against taxpayers under the Internal Revenue Code of 1939, for civil fraud, § 293(b), for delinquent failure to file returns, § 291(a), for substantial underestimation of estimated taxes, § 294(d) (2), and for the interest thereon, covering the taxable years 1951-1953.

On March 14, 1958, taxpayers filed skeleton income tax returns for the years…

2Cases cited21 opinions

  1. Helvering v. MitchellSupreme Court of the United States · 1938
  2. Jordan v. De GeorgeSupreme Court of the United States · 1951
  3. Emich Motors Corp. v. General Motors Corp.Supreme Court of the United States · 1951
  4. Grace M. Powell, of the Estate of O. E. Powell, Deceased v. Ralph C. Granquist, District Director of Internal RevenueCourt of Appeals for the Ninth Circuit · 1958
  5. Mitchell v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1941

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

3Cited by134 opinions

  1. Stone v. CommissionerUnited States Tax Court · 1971
  2. Otsuki v. CommissionerUnited States Tax Court · 1969
  3. Haldane M. Plunkett v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1972
  4. Amos v. CommissionerUnited States Tax Court · 1964
  5. McGee v. CommissionerUnited States Tax Court · 1973

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