Baker v. Commissioner
United States Tax Court
Held, upon the facts the assessment and collection of the deficiencies and additions to tax because of fraud herein determined are not precluded by reason of a compromise within the purview of section 3761, Internal Revenue Code of 1939.
1Opinion of the Court
OPINION.
BRUCE, Judge:
Petitioner filed fraudulent income tax returns containing substantial understatements of income for each of the years 1944, 1945, and 1946. Thereafter, upon advice of counsel and after an investigation had been begun by internal revenue agents, petitioner filed amended returns disclosing additional income and deficiencies in tax, to which he added 5 per cent as penalties for negligence and interest to October 15,1947, the date of filing. On the same date he paid all the tax, penalty, and interest shown thereon for the years 1944 and 1945 and a portion of the tax for the…
2Cases cited9 opinions
- Botany Worsted Mills v. United StatesSupreme Court of the United States · 1929
- L. Loewy & Son v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1929
- Backus v. United StatesUnited States Court of Claims · 1932
- Bank of New York v. United StatesCourt of Appeals for the Third Circuit · 1948
- Rau v. United StatesCourt of Appeals for the Second Circuit · 1919
4 more not listed; retrieve them via the Exa API.
3Cited by19 opinions
- Boulez v. CommissionerUnited States Tax Court · 1981
- Estate of Meyer v. CommissionerUnited States Tax Court · 1972
- Cole v. CommissionerUnited States Tax Court · 1958
- Parks v. CommissionerUnited States Tax Court · 1959
- United States v. SaladoffDistrict Court, E.D. Pennsylvania · 1964
14 more not listed; retrieve them via the Exa API.