Wodehouse v. Commissioner
United States Tax Court
1. Petitioner, a British subject, or his agent, filed income tax returns for the years 1923 and 1924. Assessment and collection of taxes for such years barred by statute of limitations. 2. Imposition of fraud penalty for year 1937 not sustained. 3. Omissions from gross income for year 1937 less than 25 per cent thereof.
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1. Petitioner, a British subject, or his agent, filed income tax returns for the years 1923 and 1924. Assessment and collection of taxes for such years barred by statute of limitations. 2. Imposition of fraud penalty for year 1937 not sustained. 3. Omissions from gross income for year 1937 less than 25 per cent thereof. Statute of limitations has tolled as to that year. 4. Alleged assignments to his wife of undivided one-half interest of petitioner in novels, etc., written by him, held to be, for purpose of securing tax advantages, equivalent to community property status in California which…
1Opinion of the Court
Van Fohsan, Judge:
The respondent determined deficiencies in the petitioner’s income tax liabilities and imposed penalties as follows:
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The petitioner claimed overpayments of $1,121.89, $3,156.82, and $14,290.12 for the years 1938, 1940, and 1941, respectively.
The cases before us present a number of issues, some common to two or more of the taxable years and some peculiar to a single year. They are best stated by relating them to the several taxable years. The facts pertinent to such issues and the opinions thereon will be set forth in the same manner.
The petitioner is a British…
2Cases cited2 opinions
- Blair v. Oesterlein MacHine Co.Supreme Court of the United States · 1927
- Rohmer v. CommissionerUnited States Tax Court · 1945
3Cited by10 opinions
- Daniel M. Cory and Margot Cory, His Wife, Petitioners-On-Review v. Commissioner of Internal Revenue, Respondent-On-ReviewCourt of Appeals for the Second Circuit · 1956
- Cory v. CommissionerUnited States Tax Court · 1955
- Goosen v. CommissionerUnited States Tax Court · 2011
- Wodehouse v. CommissionerUnited States Tax Court · 1950
- Commissioner v. WodehouseSupreme Court of the United States · 1949
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