Legal Opinion

Stages v. Commissioner

United States Tax Court

Decided September 28, 1961No. Docket Nos. 65038-65040, 65368Unpublished

1. Held, the deficiency for 1949, the year when LaVerne filed no return and no declaration of estimated tax and the additions to tax imposed under sections 291(a) and 294(d)(1)(A), I.R.C. 1939, are sustained; held, further, the addition to tax under section 293(b), I.R.C. 1939, for fraud is not sustained. 2. Held, the returns filed by petitioner's husband, Walter C. Burer, as joint returns of himself and wife LaVerne were not joint returns but were the separate returns of…

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1. Held, the deficiency for 1949, the year when LaVerne filed no return and no declaration of estimated tax and the additions to tax imposed under sections 291(a) and 294(d)(1)(A), I.R.C. 1939, are sustained; held, further, the addition to tax under section 293(b), I.R.C. 1939, for fraud is not sustained. 2. Held, the returns filed by petitioner's husband, Walter C. Burer, as joint returns of himself and wife LaVerne were not joint returns but were the separate returns of Walter. LaVerne did not sign them, she did not authorize the signing of her name to them, and she did not know anything…

1Opinion of the Court

LaVerne S. Stages, et al., 1 v. Commissioner.

Stages v. Commissioner

Docket Nos. 65038-65040, 65368.

United States Tax Court

T.C. Memo 1961-267; 1961 Tax Ct. Memo LEXIS 79; 20 T.C.M. (CCH) 1390; T.C.M. (RIA) 61267;

September 28, 1961

1. Held, the deficiency for 1949, the year when LaVerne filed no return and no declaration of estimated tax and the additions to tax imposed under sections 291(a) and 294(d)(1)(A), I.R.C. 1939, are sustained; held, further, the addition to tax under section 293(b), I.R.C. 1939, for fraud is not sustained.

2. Held, the returns filed by petitioner's husband, Walter C.…

2Cases cited26 opinions

  1. Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
  2. National Carbide Corp. v. CommissionerSupreme Court of the United States · 1949
  3. SoRelle v. CommissionerUnited States Tax Court · 1954
  4. Jones v. HelveringCourt of Appeals for the D.C. Circuit · 1934
  5. Frank Nelson, Jr. And Lee Etta Nelson v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1960

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