Legal Opinion
David Bruce McMahan v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided May 23, 1997No. 96-4083PublishedCited by 49 opinions
1Opinion of the Court
CARDAMONE, Circuit Judge.
David Bruce McMahan appeals from the decision of the United States Tax Court (Foley, J.), entered on February 6,1996, sustaining the Commissioner’s imposition of a late-filing penalty pursuant to 26 U.S.C. § 6651(a)(1) for the untimely filing of his 1982 personal income tax return. His appeal requires us to consider whether, as a matter of law, reliance on an agent to file an application for an extension of time to file a federal tax return constitutes reasonable cause for failure to file the return timely, and thereby exempts taxpayer from the late-filing penalty…
2Cases cited16 opinions
- United States v. BoyleSupreme Court of the United States · 1985
- Haywood Lumber & Mining Co. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1950
- Sanderling, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1978
- United States v. Richard L. Kroll, of the Estate of Gertrude O'reilly, DeceasedCourt of Appeals for the Seventh Circuit · 1977
- Girard Inv. Co. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1941
11 more not listed; retrieve them via the Exa API.
3Cited by49 opinions
- Priscilla M. Lippincott Adams v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1999
- Gerald B. Lefcourt, P.C. v. United StatesCourt of Appeals for the Second Circuit · 1997
- Fran Corp. v. United StatesCourt of Appeals for the Second Circuit · 1999
- Stephen Marrin and Jane Marrin v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1998
- Paschall v. CommissionerUnited States Tax Court · 2011
44 more not listed; retrieve them via the Exa API.