Legal Opinion
Casper W. Marsellus v. Commissioner of Internal Revenue
Court of Appeals for the Fifth Circuit
Decided January 3, 1977No. 76-2360PublishedCited by 74 opinions
1Opinion of the Court
TJOFLAT, Circuit Judge:
In this appeal, Casper W. Marsellus questions a Tax Court decision assessing against him the 50% penalty for civil fraud under section 6653(b) of the 1954 Internal Revenue Code. 1 In the proceedings below, the Tax Court determined that, for the period of 1960 through 1970, Marsellus had aggregated a basic tax deficiency of $221,712.58. To this sum the court then added 50% of Marsellus’ tax deficiency on a year-to-year basis, increasing his total debt to the United States by $110,856.31. On this appeal, Marsellus does not dispute the validity of the Tax Court’s…
2Cases cited6 opinions
- Chris D. Stoltzfus and Irma H. Stoltzfus v. United StatesCourt of Appeals for the Third Circuit · 1968
- Bolen Webb and Cornelia Webb v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1968
- Acker v. CommissionerUnited States Tax Court · 1956
- A. Raymond Jones and Mary Lou Jones, Husband and Wife v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1958
- Sam Goldberg v. Commissioner of Internal Revenue, Sam Goldberg and Estate of Evelyn Goldberg, Sam Goldberg v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1956
1 more not listed; retrieve them via the Exa API.
3Cited by74 opinions
- Petzoldt v. CommissionerUnited States Tax Court · 1989
- Joseph Solomon v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1984
- Clayton M. Korecky, Jr. v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1986
- Castillo v. CommissionerUnited States Tax Court · 1985
- Luther R. Patton v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1986
69 more not listed; retrieve them via the Exa API.