Legal Opinion

Karl and Hilda Hope, in Nos. 71-1993, 71-1994 v. Commissioner of Internal Revenue, in No. 71-1995

Court of Appeals for the Third Circuit

Decided January 9, 1973No. 71-1993 to 71-1995PublishedCited by 39 opinions

1Opinion of the Court

OPINION OF THE COURT

GIBBONS, Circuit Judge.

The taxpayers, Karl and Hilda Hope, appeal from a decision of the United States Tax Court, 55 T.C. 1020, determining a deficiency in income tax for the taxable year 1960 in the amount of $985,459.00. The Commissioner has filed a protective appeal from the Tax Court decision determining an overpayment of $137,775.00 in the year 1961. Taxpayer has filed a cross appeal with respect to the year 1961.

The taxpayers have filed calendar year tax returns on the cash receipts and disbursements method of accounting. Prior to the years in issue Karl Hope was the…

2Cases cited16 opinions

  1. North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
  2. James v. United StatesSupreme Court of the United States · 1961
  3. Burnet v. Sanford & Brooks Co.Supreme Court of the United States · 1931
  4. United States v. LewisSupreme Court of the United States · 1951
  5. United States v. MerrillCourt of Appeals for the Ninth Circuit · 1954

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

3Cited by39 opinions

  1. Church of Scientology v. CommissionerUnited States Tax Court · 1984
  2. Professional Ins. Agents v. CommissionerUnited States Tax Court · 1982
  3. Nordberg v. CommissionerUnited States Tax Court · 1982
  4. Pahl v. CommissionerUnited States Tax Court · 1976
  5. Lizzie W. Calloway v. Commissioner of IRSCourt of Appeals for the Eleventh Circuit · 2012

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

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