Legal Opinion
Floyd R. Clodfelter and Enna L. Clodfelter v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided May 6, 1970No. 22924_1PublishedCited by 61 opinions
1Opinion of the Court
TRASK, Circuit Judge.
Floyd R. Clodfelter and his wife, Enna, petition for review of an order and decision of the Tax Court of the United States which determined they were liable for a deficiency of $219,590.50 in payment of federal income taxes for the year 1957. The liability is said to result from a series of transactions involving the Waldorf Hotel located in Seattle, Washington. The decision of the Tax Court is reported at 48 T.C. 694. Our jurisdiction is properly invoked under Section 7482 of the Internal Revenue Code of 1954, 26 U.S.C. § 7482.
The legal issues for decision are as follows:
2Cases cited14 opinions
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Burnet v. LoganSupreme Court of the United States · 1931
- Commissioner of Internal Revenue v. Union Pac. R. Co.Court of Appeals for the Second Circuit · 1936
- Commissioner of Internal Revenue v. SegallCourt of Appeals for the Sixth Circuit · 1940
- Clodfelter v. CommissionerUnited States Tax Court · 1967
9 more not listed; retrieve them via the Exa API.
3Cited by61 opinions
- Estate of Charles T. Franklin, Deceased v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1976
- Baird v. CommissionerUnited States Tax Court · 1977
- Yelencsics v. CommissionerUnited States Tax Court · 1980
- Derr v. CommissionerUnited States Tax Court · 1981
- Edgar v. CommissionerUnited States Tax Court · 1971
56 more not listed; retrieve them via the Exa API.