Kilpatrick v. Commissioner
United States Tax Court
1. Conviction for income tax evasion on plea of nolo contendere held admissible to impeach a witness. 2. Payments made by petitioner on behalf of her two employees and her subsequent entry into a partnership agreement with them held, on facts, not to be compensation for services. 3. Petitioner's gross understatement of income accompanied by other circumstances held, on facts, to constitute fraud with intent to evade tax. 4. Respondent's computation of petitioner's 1943 tax…
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1. Conviction for income tax evasion on plea of nolo contendere held admissible to impeach a witness. 2. Payments made by petitioner on behalf of her two employees and her subsequent entry into a partnership agreement with them held, on facts, not to be compensation for services. 3. Petitioner's gross understatement of income accompanied by other circumstances held, on facts, to constitute fraud with intent to evade tax. 4. Respondent's computation of petitioner's 1943 tax liability by including part of 1942 income under Current Tax Payment Act of 1943 held erroneous in view of petitioner's…
1Opinion of the Court
Lillian Kilpatrick, Petitioner, v. Commissioner of Internal Revenue, Respondent
Kilpatrick v. Commissioner
Docket No. 37233
United States Tax Court
22 T.C. 446; 1954 U.S. Tax Ct. LEXIS 194;
May 28, 1954, Filed May 28, 1954, Filed
Decision will be entered under Rule 50.
1. Conviction for income tax evasion on plea of nolo contendere held admissible to impeach a witness.
2. Payments made by petitioner on behalf of her two employees and her subsequent entry into a partnership agreement with them held, on facts, not to be compensation for services.
3. Petitioner's gross understatement of income…
2Cases cited24 opinions
- Spies v. United StatesSupreme Court of the United States · 1943
- Halle v. CommissionerUnited States Tax Court · 1946
- Halle v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1949
- Switzer v. CommissionerUnited States Tax Court · 1953
- Cohen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1949
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