Legal Opinion

Commissioner of Internal Revenue v. Kenneth H., Susan L., Fred F., and Corinne B. Van Raden

Court of Appeals for the Ninth Circuit

Decided July 13, 1981No. 79-7486PublishedCited by 45 opinions

1Opinion of the Court

REINHARDT, Circuit Judge:

The Commissioner of Internal Revenue (Commissioner) issued notices of deficiency against the Van Radens showing $206,539 additional personal income tax due for calendar year 1972. The deficiency notices were based on a determination that the deduction of prepaid cattle feed expense in 1972 constituted a material distortion of income. See I.R.C. § 446(b). The Tax Court held that the deduction did not result in a distortion of income and set aside the deficiencies. We affirm, although not for the reasons stated by the Tax Court.

I. INTRODUCTION

In July of 1972, Kenneth…

2Cases cited7 opinions

  1. United States v. CattoSupreme Court of the United States · 1966
  2. Van Raden v. CommissionerUnited States Tax Court · 1979
  3. R D. And Ida M. Cravens v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1959
  4. Martin J. And Margaret M. Zaninovich and Vincent M. And Dorothy F. Zaninovich v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1980
  5. Clement v. United StatesUnited States Court of Claims · 1978

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3Cited by45 opinions

  1. E.A. Brannen and Frances K. Brannen v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1984
  2. Brannen v. CommissionerUnited States Tax Court · 1982
  3. Seligman v. CommissionerUnited States Tax Court · 1985
  4. Packard v. CommissionerUnited States Tax Court · 1985
  5. Ansley-Sheppard-Burgess Co. v. CommissionerUnited States Tax Court · 1995

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

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