Legal Opinion
Badaracco v. Commissioner
Court of Appeals for the Third Circuit
Decided November 29, 1982No. Nos. 81-3033, 82-5171PublishedCited by 10 opinions
1Opinion of the Court
OPINION OF THE COURT
ADAMS, Circuit Judge.
These two appeals1 concern the effect of filing nonfraudulent, amended income tax returns, subsequent to the filing of fraudulent original returns, on the statute of limitations provisions of 26 U.S.C. § 6501.2
I
The facts in each proceeding are undisputed.3 In the first case, Ernest Badaracco, Sr. and Ernest Badaracco, Jr. were equal *300partners in an electrical contracting business, Badaracco Brothers and Company. They filed individual and partnership returns for the years 1965 to 1969, which fraudulently understated their taxable income. After federal…
2Cases cited21 opinions
- United States v. LaSalle National BankSupreme Court of the United States · 1978
- Espinoza v. CommissionerUnited States Tax Court · 1982
- Ellis Campbell, Jr., District Director of Internal Revenue v. J. M. Eastland and Montez EastlandCourt of Appeals for the Fifth Circuit · 1962
- Zellerbach Paper Co. v. HelveringSupreme Court of the United States · 1934
- Bennett v. CommissionerUnited States Tax Court · 1958
16 more not listed; retrieve them via the Exa API.
3Cited by10 opinions
- Evans Cooperage Co., Inc. v. United StatesCourt of Appeals for the Fifth Circuit · 1983
- Taylor v. CommissionerUnited States Tax Court · 1999
- Beagles v. Comm'rUnited States Tax Court · 2003
- Robert M. Nesmith v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1983
- Ernest Badaracco, Sr. And Rose Badaracco, Ernest Badaracco, Jr. And Barbara Badaracco v. Commissioner of Internal Revenue, in No. 81-3033. Deleet Merchandising Corp. v. United States of America, in No. 82-5171Court of Appeals for the Third Circuit · 1982
5 more not listed; retrieve them via the Exa API.