Legal Opinion
Paul F. Gray, Jr. v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
Decided June 6, 1983No. 81-1389PublishedCited by 63 opinions
1Opinion of the Court
WESLEY E. BROWN, Senior District Judge.
This is an appeal from a decision of the United States Tax Court which sustained the Commissioner’s determination of certain deficiencies in the federal tax returns of appellant, Paul F. Gray, Jr., for the years 1968, 1969, and 1970, which imposed certain fraud penalties pursuant to 26 U.S.C. § 6653(b). In particular, the Tax Court found that Gray was collaterally estopped from denying that his returns for the years in question were fraudulent, in view of his previous pleas of guilty to charges of income tax evasion for those years.
The only issue…
2Cases cited14 opinions
- United States v. International Building Co.Supreme Court of the United States · 1953
- Haldane M. Plunkett v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1972
- Amos v. CommissionerUnited States Tax Court · 1964
- John W. Amos v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1965
- Arctic Ice Cream Co. v. CommissionerUnited States Tax Court · 1964
9 more not listed; retrieve them via the Exa API.
3Cited by63 opinions
- Kawashima v. HolderSupreme Court of the United States · 2012
- Wright v. CommissionerUnited States Tax Court · 1985
- Nelson M. Blohm and Joann M. Blohm v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1993
- Kelley v. CarrDistrict Court, W.D. Michigan · 1983
- Leo Manzoli and Mary Ann Manzoli v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1990
58 more not listed; retrieve them via the Exa API.