Legal Opinion

Jacobs v. United States

United States Court of Claims

Decided November 30, 1954No. 483-52PublishedCited by 11 opinions

1Opinion of the CourtJones, Chief Judge

Plaintiff brought this action to recover $293,759.50 taxes, penalties, and interest which he alleges the defendant has collected illegally.

Plaintiff filed returns, on a fiscal year basis (ending October 31), for each of the years 1944,1945,1946 and 1947. The Commissioner of Internal Revenue made deficiency assessments using an increase in net worth computation for these same years. He subsequently collected the deficiency together with penalty and interest, and plaintiff in turn filed a timely claim for refund. The following table shows the amounts involved:

*3

During tlie years in question…

2Cases cited6 opinions

  1. Reinecke v. SpaldingSupreme Court of the United States · 1930
  2. Hague Estate v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1943
  3. Goe v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1952
  4. Hoefle v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1940
  5. Ratto v. CommissionerUnited States Tax Court · 1953

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

3Cited by11 opinions

  1. Carlos and Jacqueline Marcello v. Commissioner of Internal Revenue, Joseph, Jr. And Anastasia Marcello v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1967
  2. Murl Clark v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1958
  3. Kellogg-Citizens National Bank of Green Bay, Wisconsin, of the Estate of Joseph B. Holzer, Deceased v. The United StatesUnited States Court of Claims · 1964
  4. Lazarus v. United StatesUnited States Court of Claims · 1956
  5. Robert Azevedo, Irene Kershaw, and Paul Kershaw, J. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1957

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

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