Cirillo v. Commissioner
United States Tax Court
Held, a part of the deficiency for each of the years 1945 to 1954, inclusive, was due to fraud with intent to evade tax within the meaning of section 293(b), I.R.C. 1939, and section 6653(b), I.R.C. 1954. Held, petitioner Martha R. Cirillo is not liable for the additions to tax under section 293(b), I.R.C. 1939, and section 6653(b), I.R.C. 1954. Held, additions to tax under sections 293(b) and 6653(b) are based upon the correct tax liabilities without regard to credit for…
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Held, a part of the deficiency for each of the years 1945 to 1954, inclusive, was due to fraud with intent to evade tax within the meaning of section 293(b), I.R.C. 1939, and section 6653(b), I.R.C. 1954. Held, petitioner Martha R. Cirillo is not liable for the additions to tax under section 293(b), I.R.C. 1939, and section 6653(b), I.R.C. 1954. Held, additions to tax under sections 293(b) and 6653(b) are based upon the correct tax liabilities without regard to credit for income taxes withheld. Held, petitioners are not entitled to credit against additions to tax for overpayment for the year…
1Opinion of the Court
Joseph A. Cirillo and Martha R. Cirillo v. Commissioner.
Cirillo v. Commissioner
Docket No. 79981.
United States Tax Court
T.C. Memo 1961-192; 1961 Tax Ct. Memo LEXIS 157; 20 T.C.M. (CCH) 956; T.C.M. (RIA) 61192;
June 29, 1961
Held, a part of the deficiency for each of the years 1945 to 1954, inclusive, was due to fraud with intent to evade tax within the meaning of section 293(b), I.R.C. 1939, and section 6653(b), I.R.C. 1954.
Held, petitioner Martha R. Cirillo is not liable for the additions to tax under section 293(b), I.R.C. 1939, and section 6653(b), I.R.C. 1954.
Held, additions to tax under…
2Cases cited16 opinions
- Spies v. United StatesSupreme Court of the United States · 1943
- 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
- Acker v. CommissionerUnited States Tax Court · 1956
- Howell v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1949
- Howell v. CommissionerUnited States Tax Court · 1948
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3Cited by2 opinions
- Maria Spanos v. United StatesCourt of Appeals for the Fourth Circuit · 1963
- Spanos v. United StatesDistrict Court, D. Maryland · 1963