Legal Opinion

Chesterfield Textile Corp. v. Commissioner

United States Tax Court

Decided January 13, 1958No. Docket Nos. 56542, 56543Published

1. Returns filed by petitioners, held, on the facts, fraudulent with intent to evade tax, making statute of limitations inapplicable. 2. Deficiencies determined, held, on the facts, not shown to be improper. 3. Part of each deficiency for both petitioners, held, on the facts, due to fraud. 4. A document denominated "tentative return," held, on the facts, not a proper return under section 51, I. R. C. 1939, and addition to tax for failure to file on time properly imposed.

1Opinion of the Court

Chesterfield Textile Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent. Sam Novick, Petitioner, v. Commissioner of Internal Revenue, Respondent

Chesterfield Textile Corp. v. Commissioner

Docket Nos. 56542, 56543

United States Tax Court

29 T.C. 651; 1958 U.S. Tax Ct. LEXIS 280;

January 13, 1958, Filed

Decisions will be entered for the respondent.

1. Returns filed by petitioners, held, on the facts, fraudulent with intent to evade tax, making statute of limitations inapplicable.

2. Deficiencies determined, held, on the facts, not shown to be improper.

3. Part of each deficiency…

2Cases cited9 opinions

  1. Zellerbach Paper Co. v. HelveringSupreme Court of the United States · 1934
  2. Cohen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1949
  3. Cohen v. CommissionerUnited States Tax Court · 1947
  4. Kilpatrick v. CommissionerUnited States Tax Court · 1954
  5. Lillian Kilpatrick v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. Lillian KilpatrickCourt of Appeals for the Fifth Circuit · 1955

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