Lentin v. Commissioner
United States Tax Court
A United States District Court determined that petitioner and a co-venturer willfully violated the Emergency Price Control Act of 1942, as amended. Its decision was affirmed on appeal.
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A United States District Court determined that petitioner and a co-venturer willfully violated the Emergency Price Control Act of 1942, as amended. Its decision was affirmed on appeal. Petitioner paid his share of the judgment in the amount of $ 34,985.94 in 1946, and claimed a deduction of that amount on his return for that year. 1. Held, the determination of the District Court that petitioner's violation of the Price Control Act was willful is res judicata as to the issue of willfulness in this proceeding. 2. Held, further, petitioner may not deduct the amount paid pursuant to a judgment…
1Opinion of the Court
OPINION.
Rice, Judge:
This proceeding involves a deficiency in income tax of $16,676.34 determined against petitioner, Julian Lentin, for the year 1946. The sole issue to be decided is whether the amount of $34,985.94 paid by petitioner in 1946 pursuant to a judgment entered against him by a United States District Court for willful violation of the Emergency Price Control Act of 1942,1 as amended, is deductible by him in whole or in part on his return for that year.
All of the facts were stipulated, are so found, and are incorporated herein by this reference.
Petitioner was a resident of Chicago,…
2Cases cited13 opinions
- Sunshine Anthracite Coal Co. v. AdkinsSupreme Court of the United States · 1940
- Sullenger v. CommissionerUnited States Tax Court · 1948
- Jerry Rossman Corporation v. Commissioner of Int. Rev.Court of Appeals for the Second Circuit · 1949
- United States v. Willard Tablet Co.Court of Appeals for the Seventh Circuit · 1944
- National Brass Works, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1950
8 more not listed; retrieve them via the Exa API.
3Cited by16 opinions
- Suarez v. CommissionerUnited States Tax Court · 1972
- Boyle, Flagg & Seaman, Inc. v. CommissionerUnited States Tax Court · 1955
- Wm. T. Stover Co. v. CommissionerUnited States Tax Court · 1956
- Julian Lentin v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1955
- Mesi v. CommissionerUnited States Tax Court · 1955
11 more not listed; retrieve them via the Exa API.