Legal Opinion

Owens v. United States

District Court, W.D. Arkansas

Decided July 2, 1951No. Civ. 268PublishedCited by 15 opinions

1Opinion of the Court

JOHN E. MILLER, District Judge.

This is a suit by the plaintiff to recover fraud penalties assessed against him and paid for the calendar years 1944, 1945, 1946 and 1947. The correctness of the deficiency assessments for the said years paid by the plaintiff is not here attacked, and the sole issue before the court is whether civil fraud penalties were properly assessed and collected by the Commissioner of Internal Revenue. To resolve this issue the court must determine whether the admitted deficiencies for the years in question were due to “fraud with intent to evade tax” within the meaning of…

2Cases cited8 opinions

Helvering v. MitchellSupreme Court of the United States · 1938
Mitchell v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1941
Halle v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1949
Rogers v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1940
Battjes v. United StatesCourt of Appeals for the Sixth Circuit · 1949

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

3Cited by15 opinions

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
The Barr Rubber Products Company, Plaintiff-Appellee-Cross v. The Sun Rubber Company, Defendant-Appellant-Cross and Wonder Products CompanyCourt of Appeals for the Second Circuit · 1970
B. B. Carter and Mrs. Tommie v. Carter v. Ellis Campbell, Jr., Director of Internal RevenueCourt of Appeals for the Fifth Circuit · 1959
Miller v. Kasden (In Re Kasden)United States Bankruptcy Appellate Panel for the Eighth Circuit · 1997
United States v. Cecil Thompson, Cecil Thompson, Cross-Appellant v. United States of America, Cross-AppelleeCourt of Appeals for the Tenth Circuit · 1960

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