Legal Opinion

Snell Isle, Inc. v. Commissioner of Internal Revenue

Court of Appeals for the Fifth Circuit

Decided June 9, 1937No. 8279PublishedCited by 29 opinions

1Opinion of the Court

FOSTER, Circuit Judge.

The Commissioner of Internal Revenue determined deficiencies in income taxes of petitioner for the fiscal years ending April 30, 1926, to April 30, 1929, both inclusive, amounting to $34,894.54. Deeming the returns were fraudulent, he also assessed a penalty of 50 per cent, in addition. Petitioner appealed to the Board of Tax Appeals. The Commissioner answered, affirmatively pleading fraud in the preparation and filing of the returns. The Board found that the Commissioner had not sustained the burden of proving fraud and decided against him on that ground. But the Board…

2Cases cited1 opinion

  1. Remington v. LinthicumSupreme Court of the United States · 1840

3Cited by29 opinions

  1. William J. Drieborg and Laura D. Drieborg v. Commissioner of Internal Revenue, William J. Drieborg v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1955
  2. B. B. Carter and Mrs. Tommie v. Carter v. Ellis Campbell, Jr., Director of Internal RevenueCourt of Appeals for the Fifth Circuit · 1959
  3. Bryan Et Ux. v. Commissioner of Internal Revenue. Bryan v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1954
  4. Cohen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1949
  5. Carmack Et Ux. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1950

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