Legal Opinion

Franklin v. Commissioner

United States Tax Court

Decided April 26, 1993No. Docket No. 15188-89UnpublishedCited by 27 opinions

Petitioner pled guilty to conducting a continuing criminal enterprise involving heroin sales for the period June 1982 through mid-July 1987 and to willfully making a false return by failing to include income and expenses from heroin distribution in his 1983 Federal income tax return. Respondent determined deficiencies and additions to tax for petitioner's taxable years 1982 and 1983 relating to unreported narcotics income.

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Petitioner pled guilty to conducting a continuing criminal enterprise involving heroin sales for the period June 1982 through mid-July 1987 and to willfully making a false return by failing to include income and expenses from heroin distribution in his 1983 Federal income tax return. Respondent determined deficiencies and additions to tax for petitioner's taxable years 1982 and 1983 relating to unreported narcotics income. Petitioner challenged the deficiency notice on the grounds that it was arbitrary. 1. Held: The notice of deficiency is nonarbitrary as to both 1982 and 1983. 2. Held,…

1Opinion of the Court

WILLIAM FRANKLIN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Franklin v. Commissioner

Docket No. 15188-89

United States Tax Court

T.C. Memo 1993-184; 1993 Tax Ct. Memo LEXIS 181; 65 T.C.M. (CCH) 2497;

April 26, 1993, Filed

Decision will be entered under Rule 155.

Petitioner pled guilty to conducting a continuing criminal enterprise involving heroin sales for the period June 1982 through mid-July 1987 and to willfully making a false return by failing to include income and expenses from heroin distribution in his 1983 Federal income tax return. Respondent determined deficiencies and…

2Cases cited35 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
  3. United States v. JanisSupreme Court of the United States · 1976
  4. Helvering v. TaylorSupreme Court of the United States · 1935
  5. Beaver v. CommissionerUnited States Tax Court · 1970

30 more not listed; retrieve them via the Exa API.

3Cited by27 opinions

  1. Californians Helping to Alleviate Med. Problems, Inc. v. Comm'rUnited States Tax Court · 2007
  2. Williamson v. CommissionerUnited States Tax Court · 1993
  3. Langworthy v. CommissionerUnited States Tax Court · 1998
  4. Hughes v. CommissionerUnited States Tax Court · 1994
  5. Barrow v. Comm'rUnited States Tax Court · 2008

22 more not listed; retrieve them via the Exa API.

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