Legal Opinion
Patterson v. Sims
Court of Appeals for the Fifth Circuit
Decided August 5, 1960No. 18121PublishedCited by 39 opinions
1Opinion of the Court
RIVES, Chief Judge.
This appeal and cross-appeal concern the extent of the liability for interest of a transferee of property1 of a delinquent income taxpayer.
The facts were stipulated and may be briefly summarized. On March 13, 1950, delinquent income taxes for the years 1946 and 1947 were assessed against Jennie M. Brown, totalling for both years $39,792.48, taxes, plus $5,406.28, interest, and $19,752.25, penalty, or an aggregate of $64,951.01. This assessment has not been paid. A federal tax lien against Jennie M. Brown was not filed until November 26, 1952.
Meanwhile, on January 15, 1951,…
2Cases cited8 opinions
- United States v. BessSupreme Court of the United States · 1958
- Commissioner v. SternSupreme Court of the United States · 1958
- Gordon, Rankin & Co. v. TweedySupreme Court of Alabama · 1881
- Caldwell v. KingSupreme Court of Alabama · 1884
- Potter & Son v. GracieSupreme Court of Alabama · 1877
3 more not listed; retrieve them via the Exa API.
3Cited by39 opinions
- Mysse v. CommissionerUnited States Tax Court · 1972
- Stein v. CommissionerUnited States Tax Court · 1962
- Lowy v. CommissionerUnited States Tax Court · 1960
- Bos Lines, Inc., Transferee v. Commissioner of Internal Revenue, Bos Lines, Inc., Transferee of the Transferee v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1965
- Poinier v. CommissionerCourt of Appeals for the Third Circuit · 1988
34 more not listed; retrieve them via the Exa API.