Legal Opinion

Januschke v. Commissioner

United States Tax Court

Decided June 29, 1967No. Docket No. 2056-65PublishedCited by 14 opinions

Held, petitioner is not liable as a transferee of assets of Norma Nathan for an unpaid deficiency in income tax, due for the year 1952, plus an addition to the tax pursuant to sec. 293(b) of the Internal Revenue Code of 1939, and interest as provided by law.

1Opinion of the Court

Arundell, Judge:

Respondent determined that petitioner is liable

as a transferee of assets of Norma Nathan, petitioner’s daughter, for an unpaid deficiency in income tax of $2,816.88 due for the calendar year 1952, plus an addition to tax pursuant to section 293(b) of the Internal Revenue Code of 1939 of $1,408.44, plus interest as provided by law.

Petitioner has assigned two errors, as follows:(a) The Commissioner erroneously assessed a tax against the alleged trans-feror, Norma Nathan.(b) The Commissioner erred in his contention that the petitioner is a transferee of said Norma Nathan.

FINDINGS…

2Cases cited4 opinions

  1. Hennen v. CommissionerUnited States Tax Court · 1961
  2. United States v. Clarence J. PrinceCourt of Appeals for the Second Circuit · 1965
  3. Carroro v. CommissionerUnited States Board of Tax Appeals · 1933
  4. Newman & Carey Subway Constr. Co. v. CommissionerUnited States Board of Tax Appeals · 1938

3Cited by14 opinions

  1. Estate of Campbell v. CommissionerUnited States Tax Court · 1971
  2. Levitt v. CommissionerUnited States Tax Court · 1991
  3. Mendelson v. Comm'rUnited States Tax Court · 1969
  4. Carrick v. CommissionerUnited States Tax Court · 1991
  5. Griffith v. CommissionerUnited States Tax Court · 1988

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