Legal Opinion

Hughes v. Commissioner

United States Tax Court

Decided April 9, 1956No. Docket No. 38765Published

Individual Income Tax Returns -- Joint or Separate. -- Return forms captioned in the names of both spouses and signed by both, in which it was stated that no separate returns were being filed, and in which the tax was computed on aggregate income, held to be joint returns on which the wife is jointly and severally liable for the deficiencies and additions for fraud, even though the fraudulent acts were solely those of the husband.

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Individual Income Tax Returns -- Joint or Separate. -- Return forms captioned in the names of both spouses and signed by both, in which it was stated that no separate returns were being filed, and in which the tax was computed on aggregate income, held to be joint returns on which the wife is jointly and severally liable for the deficiencies and additions for fraud, even though the fraudulent acts were solely those of the husband. Schedules attached to the returns which listed separately the income and deductions of the spouses do not, in the light of other evidence, establish intent to file…

1Opinion of the Court

Dora S. Hughes, Petitioner, v. Commissioner of Internal Revenue, Respondent

Hughes v. Commissioner

Docket No. 38765

United States Tax Court

26 T.C. 23; 1956 U.S. Tax Ct. LEXIS 222;

April 9, 1956, Filed

Decision will be entered for the respondent.

Individual Income Tax Returns -- Joint or Separate. -- Return forms captioned in the names of both spouses and signed by both, in which it was stated that no separate returns were being filed, and in which the tax was computed on aggregate income, held to be joint returns on which the wife is jointly and severally liable for the deficiencies and additions…

2Cases cited10 opinions

  1. Howell v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1949
  2. Howell v. CommissionerUnited States Tax Court · 1948
  3. Kann v. Commissioner of Internal Revenue. Kann's Estate v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1954
  4. Boyett Et Ux. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1953
  5. Stone v. CommissionerUnited States Tax Court · 1954

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