Legal Opinion

Estate of Mazzoni v. Commissioner

Court of Appeals for the Third Circuit

Decided November 29, 1971No. Nos. 19338, 19339PublishedCited by 75 opinions

1Opinion of the Court

OPINION OF THE COURT

ALDISERT, Circuit Judge.

These appeals from the Tax Court question the propriety of the application here of the net worth method of reconstruction of income and the determination that the Commissioner of Internal Revenue satisfied his burden of proving fraud by the taxpayers.

Taxpayers, owners of two grocery stores in western Pennsylvania,1 petitioned the Tax Court for a redetermination of their federal income tax liabilities after the Commissioner, applying the net worth reconstruction of income method, determined that there had been unreported income, deficiencies in tax,…

2Cases cited20 opinions

  1. Holland v. United StatesSupreme Court of the United States · 1955
  2. Bolen Webb and Cornelia Webb v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1968
  3. Condor Merritt v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1962
  4. George Schwarzkopf v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1957
  5. Peter Vaira and Mary L. Vaira v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1971

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

3Cited by75 opinions

  1. Grosshandler v. CommissionerUnited States Tax Court · 1980
  2. Robert P. Lord, Appellee-Cross-Appellant v. Commissioner of Internal Revenue, Appellant-Cross-AppelleeCourt of Appeals for the Ninth Circuit · 1975
  3. Arthur Meister and Dorothy Meister v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1974
  4. Mazzocchi Bus Co. v. CommissionerCourt of Appeals for the Third Circuit · 1994
  5. Graham v. Internal Revenue Service (In Re Graham)United States Bankruptcy Court, E.D. Pennsylvania · 1989

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

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