Legal Opinion
Sanderling, Inc. v. Commissioner of Internal Revenue
Court of Appeals for the Third Circuit
Decided February 21, 1978No. 77-1599PublishedCited by 110 opinions
1Opinion of the Court
OPINION OF THE COURT
WEIS, Circuit Judge.
Whether waivers of the statute of limitations and an IRS statutory notice of deficiency were in themselves deficient is the question presented in this appeal from a redetermination by the Tax Court. We conclude taxpayer’s challenge to the statutory notice must fail. However, we do agree with the taxpayer that no penalty for late filing should be imposed because responsibility for properly preparing and filing a return was entrusted to a C.P.A. In the circumstances present here, the taxpayer’s reliance on professional assistance was not shown to be…
2Cases cited16 opinions
- Logan Lumber Company v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1966
- Haywood Lumber & Mining Co. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1950
- Hatfried, Inc. v. Commissioner of Internal Rev.Court of Appeals for the Third Circuit · 1947
- Sanderling, Inc. v. CommissionerUnited States Tax Court · 1976
- United States v. Richard L. Kroll, of the Estate of Gertrude O'reilly, DeceasedCourt of Appeals for the Seventh Circuit · 1977
11 more not listed; retrieve them via the Exa API.
3Cited by110 opinions
- United States v. BoyleSupreme Court of the United States · 1985
- Achiro v. CommissionerUnited States Tax Court · 1981
- Howard S. Scar and Ethel M. Scar v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1987
- Priscilla M. Lippincott Adams v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1999
- David Bruce McMahan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1997
105 more not listed; retrieve them via the Exa API.