Legal Opinion
Donald G. Smith v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
Decided April 22, 1991No. 90-1049PublishedCited by 87 opinions
1Opinion of the Court
SUHRHEINRICH, Circuit Judge.
Petitioner appeals from the tax court’s order denying his motion to vacate a default judgment granting the deficiency amount and fraud penalties. For the reasons stated below, the decision of the tax court is AFFIRMED.
I
On April 15, 1976, the Commissioner of Internal Revenue (“Commissioner” or “respondent”) sent a statutory notice of deficiency to petitioner, Donald G. Smith (“petitioner”), seeking deficiency taxes and fraud penalties based on alleged unreported income for the tax years 1972 and 1973. Petitioner filed a request for redetermination with the tax court…
2Cases cited42 opinions
- Link v. Wabash RailroadSupreme Court of the United States · 1962
- Welch v. HelveringSupreme Court of the United States · 1933
- Holland v. United StatesSupreme Court of the United States · 1955
- Vasquez v. HillerySupreme Court of the United States · 1986
- Helvering v. TaylorSupreme Court of the United States · 1935
37 more not listed; retrieve them via the Exa API.
3Cited by87 opinions
- William S. Hagaman, Bonnie C. Hagaman v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1992
- Richard M. Baptiste, Transferee v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1994
- North American Rayon Corporation, Formerly Known as North American Holding Corporation, Narco v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1994
- Bavely v. Powell (In Re Baskett)Bankruptcy Appellate Panel of the Sixth Circuit · 1998
- John A. Gabelman v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1996
82 more not listed; retrieve them via the Exa API.