Goodwin v. Commissioner
United States Tax Court
Held: 1. Conviction of petitioner under sec. 7206(1), I.R.C. 1954, for the same years involved in the instant case in which an addition to tax under sec. 6653(b), I.R.C. 1954, is asserted estops him from denying that his returns were false and fraudulent and that there was an omission of income from his return in each year; 2. A part of the underpayment in petitioner's tax for each of the years here in issue was due to fraud; and 3. Amount of income which petitioner failed…
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Held: 1. Conviction of petitioner under sec. 7206(1), I.R.C. 1954, for the same years involved in the instant case in which an addition to tax under sec. 6653(b), I.R.C. 1954, is asserted estops him from denying that his returns were false and fraudulent and that there was an omission of income from his return in each year; 2. A part of the underpayment in petitioner's tax for each of the years here in issue was due to fraud; and 3. Amount of income which petitioner failed to report in each year determined from the record.
1Opinion of the Court
Scott, Judge:
Respondent determined deficiencies in Federal income tax and additions to tax under section 6653(b)1 (fraud) for the calendar years and in the amounts listed below:
Additions to tax
Year Deficiency sec. 6653(b)
1968 . $1,926.30 $963.15
1969 . 2,379.31 1,189.65
1970 . 2,666.57 1,333.29
In his answer, respondent asserts that the addition to tax for 1969 should be increased by $481.18, for a total addition to tax of $1,670.83 for 1969.
The following three issues are presented for our consideration: (1) Whether petitioner is estopped by his conviction of violating section 7206(1) by filing…
2Cases cited32 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
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- Yates v. United StatesSupreme Court of the United States · 1957
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- Local 167, International Brotherhood of Teamsters v. United StatesSupreme Court of the United States · 1934
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