Brown v. Commissioner
United States Tax Court
1. Charles R. Brown (Charles) and Elmer L. Lautenberger (Elmer) were liable for income tax deficiencies and penalties for 1942 through 1946. For 1942 through 1945 they each filed returns in their individual names only and they alone signed the returns.
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1. Charles R. Brown (Charles) and Elmer L. Lautenberger (Elmer) were liable for income tax deficiencies and penalties for 1942 through 1946. For 1942 through 1945 they each filed returns in their individual names only and they alone signed the returns. The returns included minor amounts of income and deductions (from real estate held as tenants by the entireties and joint bank accounts) attributable to their respective wives, petitioners Anna and Ida; claimed dependency exemptions for their wives; and stated that their wives were not filing (and they did not so file) separate returns.…
1Opinion of the Court
OPINION.
Black, Judge:
Our attention is first directed to determination of the joint return issues raised in Docket Nos. 45015 and 45017, to wit, whether the returns filed by Charles E. Brown and Elmer L. Lauten-berger for 1942 through 1945 were, in fact, joint returns with their respective wives, Anna and Ida, thereby making the latter jointly and severally liable with their husbands for the deficiencies and fraud penalties admittedly due from Charles and Elmer for those years. The applicable provision of the Internal Eevenue Code of 1939 is printed in the margin.5
In their brief, petitioners…
2Cases cited25 opinions
- Burnet v. HoustonSupreme Court of the United States · 1931
- Healy v. CommissionerSupreme Court of the United States · 1953
- Howell v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1949
- Howell v. CommissionerUnited States Tax Court · 1948
- Milholland v. WhalenCourt of Appeals of Maryland · 1899
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3Cited by11 opinions
- Gumm v. CommissionerUnited States Tax Court · 1989
- Poinier v. CommissionerCourt of Appeals for the Third Circuit · 1988
- Yurick v. CommonwealthCommonwealth Court of Pennsylvania · 1989
- Brown v. Comm'rUnited States Tax Court · 1968
- Washington Metropolitan Area Transit Authority v. One Parcel of Land in Prince George's CountyDistrict Court, D. Maryland · 2002
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