Rodney v. Comm'r
United States Tax Court
Held: 1. Because of his criminal conviction of willful attempt to evade income tax for the years 1959 through 1962, petitioner Henry M. Rodney is collaterally estopped to deny that the joint income tax returns that he filed with his wife for the years 1959 through 1962 were false and fraudulent or that a part of the underpayment, if any, in tax for those years is due to fraud with intent to evade tax.
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Held: 1. Because of his criminal conviction of willful attempt to evade income tax for the years 1959 through 1962, petitioner Henry M. Rodney is collaterally estopped to deny that the joint income tax returns that he filed with his wife for the years 1959 through 1962 were false and fraudulent or that a part of the underpayment, if any, in tax for those years is due to fraud with intent to evade tax. Therefore, the assessment and collection of any deficiency in tax for none of those years from Henry M. Rodney is barred by the statute of limitations and he is liable for the addition to tax…
1Opinion of the Court
Scott, Judge:
Respondent determined deficiencies in petitioners’ income taxes and additions to taxes under section 6653(b), I.R.C. 1954,1 for the years and in the amounts as follows:
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The parties have disposed of a number of the issues raised by the pleadings, leaving the following for our consideration:(1) Whether assessment of deficiencies against both or either of petitioners for the years 1957 through 1959 and 1961 through 1963 is barred by the statute of limitations. For all of these years except 1963 the determination of this issue is dependent upon whether the returns filed…
2Cases cited34 opinions
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Amos v. CommissionerUnited States Tax Court · 1964
- John W. Amos v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1965
- Tomlinson v. LefkowitzCourt of Appeals for the Fifth Circuit · 1964
- Arctic Ice Cream Co. v. CommissionerUnited States Tax Court · 1964
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3Cited by99 opinions
- Stone v. CommissionerUnited States Tax Court · 1971
- Neonatology Assocs., P.A. v. Comm'rUnited States Tax Court · 2000
- Haldane M. Plunkett v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1972
- Electric & Neon, Inc. v. CommissionerUnited States Tax Court · 1971
- Stratton v. CommissionerUnited States Tax Court · 1970
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