Legal Opinion

Keeton v. Commissioner

United States Tax Court

Decided May 21, 1980No. Docket No. 7955-77PublishedCited by 85 opinions

Petitioners were criminally convicted for Federal income tax evasion for the years 1970 to 1973. The criminal proceedings were initiated by respondent's audit procedures, prosecuted upon respondent's recommendation, and participated in by respondent's agents.

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Petitioners were criminally convicted for Federal income tax evasion for the years 1970 to 1973. The criminal proceedings were initiated by respondent's audit procedures, prosecuted upon respondent's recommendation, and participated in by respondent's agents. After petitioners' appeals had been rejected, petitioner husband surrendered to the custody of Federal prison authorities and petitioner wife moved, subject to the jurisdiction of Federal probation authorities, near the Federal penitentiary in Leavenworth, Kans., where petitioner husband was imprisoned. After petitioner husband's…

1Opinion of the Court

OPINION

Dawson, Judge:

This case was assigned to and heard by Special Trial Judge Francis J. Cantrel for the purpose of conducting the hearing and ruling on respondent’s motion to dismiss for lack of jurisdiction and petitioners’ cross-motion to dismiss for lack of jurisdiction. After a review of the record, we agree with and adopt his opinion which is set forth below.1

OPINION OF THE SPECIAL TRIAL JUDGE

Cantrel, Special Trial Judge:

On August 25,1977, respondent filed a “Motion to Dismiss for Lack of Jurisdiction” on the ground that the petition was not filed within the statutory period…

2Cases cited21 opinions

  1. Meyer Harris Cohen, AKA Michael 'Mickey' Cohen v. United StatesCourt of Appeals for the Ninth Circuit · 1962
  2. Alta Sierra Vista, Inc. v. CommissionerUnited States Tax Court · 1974
  3. Moffat v. CommissionerUnited States Tax Court · 1966
  4. Lifter v. CommissionerUnited States Tax Court · 1973
  5. Commissioner of Internal Revenue v. StewartCourt of Appeals for the Sixth Circuit · 1951

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

3Cited by85 opinions

  1. Frieling v. CommissionerUnited States Tax Court · 1983
  2. Abeles v. CommissionerUnited States Tax Court · 1988
  3. Mulvania v. CommissionerUnited States Tax Court · 1983
  4. Pietanza v. CommissionerUnited States Tax Court · 1989
  5. McKay v. CommissionerUnited States Tax Court · 1987

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

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