Crawford v. Commissioner
United States Tax Court
1. Held, on the facts, respondent erred in including in petitioner's community property income one-half of amounts received by her husband from illegal sales of cattle and rental of pasture lands which he did not own. 2. Held, petitioner's failure to file income tax returns and declarations of estimated tax were not due to reasonable cause. 3. Held, the Tax Court has no authority to order respondent to credit to one taxpayer amounts of tax withheld on the income of another…
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1. Held, on the facts, respondent erred in including in petitioner's community property income one-half of amounts received by her husband from illegal sales of cattle and rental of pasture lands which he did not own. 2. Held, petitioner's failure to file income tax returns and declarations of estimated tax were not due to reasonable cause. 3. Held, the Tax Court has no authority to order respondent to credit to one taxpayer amounts of tax withheld on the income of another taxpayer or portions thereof.
1Opinion of the Court
Inez Margaret Crawford v. Commissioner.
Crawford v. Commissioner
Docket No. 77880.
United States Tax Court
T.C. Memo 1961-224; 1961 Tax Ct. Memo LEXIS 124; 20 T.C.M. (CCH) 1113; T.C.M. (RIA) 61224;
August 10, 1961
1. Held, on the facts, respondent erred in including in petitioner's community property income one-half of amounts received by her husband from illegal sales of cattle and rental of pasture lands which he did not own.
2. Held, petitioner's failure to file income tax returns and declarations of estimated tax were not due to reasonable cause.
3. Held, the Tax Court has no authority to order…
2Cases cited7 opinions
- SoRelle v. CommissionerUnited States Tax Court · 1954
- Downs v. CommissionerUnited States Tax Court · 1946
- Southeastern Finance Co. v. CommissionerUnited States Tax Court · 1945
- McKnight v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1942
- Perine v. CommissionerUnited States Board of Tax Appeals · 1931
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