Legal Opinion

United States v. Edward M. Zolla

Court of Appeals for the Ninth Circuit

Decided January 24, 1984No. 82-5947PublishedCited by 181 opinions

1Opinion of the Court

GOODWIN, Circuit Judge:

Zoila appeals a district court judgment in favor of the government in its action to reduce to judgment Zolla’s federal income tax liabilities for 1968 and 1969.

Neither the government nor Zoila introduced direct evidence of Zolla’s income and deductions for the years in question. The government relied upon the presumption of correctness that attaches to the IRS’s determination of a tax deficiency. See Rockwell v. Commissioner, 512 F.2d 882, 885 (9th Cir.), cert. denied, 423 U.S. 1015, 96 S.Ct. 448, 46 L.Ed.2d 386 (1975). Zoila argued that the presumption of correctness…

2Cases cited15 opinions

  1. Johnny Weimerskirch v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1979
  2. Michael L. Rockwell, and Regina Rockwell v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1975
  3. Cool Fuel, Incorporated v. William H. Connett, Etc.Court of Appeals for the Ninth Circuit · 1982
  4. Meyer Harris Cohen, AKA Michael 'Mickey' Cohen v. United StatesCourt of Appeals for the Ninth Circuit · 1962
  5. Alta Sierra Vista, Inc. v. CommissionerUnited States Tax Court · 1974

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

3Cited by181 opinions

  1. Sego v. CommissionerUnited States Tax Court · 2000
  2. Vincent C. Wiley v. United States of America Citizens Federal Mortgage Corporation State of Ohio Franklin County Treasurer and Houng ThaiCourt of Appeals for the Sixth Circuit · 1994
  3. Petzoldt v. CommissionerUnited States Tax Court · 1989
  4. Hughes v. United StatesCourt of Appeals for the Ninth Circuit · 1992
  5. Pyo v. CommissionerUnited States Tax Court · 1984

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

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