Legal Opinion
Lesly Cohen v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided April 8, 1959No. 15982PublishedCited by 74 opinions
1Opinion of the Court
HAMLEY, Circuit Judge.
This matter is before us on a taxpayer’s petition to review a decision of the Tax Court redetermining income tax deficiencies and penalties for 1948, 1949, and 1950. The principal question we have to decide is this: Where the Tax Court has rejected the deficiency determination of the Commissioner of Internal Revenue, may it redetermine the deficiency by finding that “it is not likely” that gross income exceeded a certain figure (substantially below that found by the Commissioner) and then utilize that figure as actual gross income because petitioner failed to establish a…
2Cases cited12 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Helvering v. TaylorSupreme Court of the United States · 1935
- Grace M. Powell, of the Estate of O. E. Powell, Deceased v. Ralph C. Granquist, District Director of Internal RevenueCourt of Appeals for the Ninth Circuit · 1958
- William J. Drieborg and Laura D. Drieborg v. Commissioner of Internal Revenue, William J. Drieborg v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1955
- Bryan Et Ux. v. Commissioner of Internal Revenue. Bryan v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1954
7 more not listed; retrieve them via the Exa API.
3Cited by74 opinions
- Robert W. Bradford v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1986
- Michael L. Rockwell, and Regina Rockwell v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1975
- Estate of Mason v. CommissionerUnited States Tax Court · 1975
- Seymour Silverman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1976
- Marie H. Hamm v. Commissioner of Internal Revenue, William Hamm, Jr. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1963
69 more not listed; retrieve them via the Exa API.