Legal Opinion
William Levinson and William Levinson, Assignee of F.M.P. Corporation, Formerly Known as Fairmount Motor Products Co., Inc. v. United States
Court of Appeals for the Third Circuit
Decided May 8, 1974No. 73-1909PublishedCited by 66 opinions
1Opinion of the Court
OPINION OF THE COURT
JAMES HUNTER, III, Circuit Judge:
The sole issue on this appeal is the determination of the proper method by which civil tax fraud penalties are to be assessed under 26 U.S.C. § 6653. The Internal Revenue Service (“IRS”) assessed a 50% fraud penalty on the difference between taxpayers’ true tax liability and the tax liability shown on taxpayers’ original tax returns. The district court upheld this method of computation and we affirm.
Taxpayers’ returns for 1967 through 1959 were timely filed and the taxes shown thereon timely paid. When the IRS subsequently conducted routine…
2Cases cited8 opinions
- United States v. American Trucking AssociationsSupreme Court of the United States · 1940
- George M. Still, Inc. v. CommissionerUnited States Tax Court · 1953
- Wilson v. CommissionerUnited States Tax Court · 1946
- Kurtzon v. CommissionerUnited States Tax Court · 1952
- Joseph N. Romm and Helen K. Romm, His Wife v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1957
3 more not listed; retrieve them via the Exa API.
3Cited by66 opinions
- Breman v. CommissionerUnited States Tax Court · 1976
- Drobny v. CommissionerUnited States Tax Court · 1986
- Danenberg v. CommissionerUnited States Tax Court · 1979
- Stewart v. CommissionerUnited States Tax Court · 1976
- Frazier v. CommissionerUnited States Tax Court · 1988
61 more not listed; retrieve them via the Exa API.