Legal Opinion

Amos v. Commissioner

United States Tax Court

Decided October 21, 1964No. Docket No. 4476-62Published

Held, petitioner's conviction for willful attempted evasion of income taxes for the years 1955 through 1958 in violation of section 7201, I.R.C. 1954, necessarily carries with it the ultimate factual determination that a part of the resulting deficiencies for those years was "due to fraud" within the purview of section 6653(b), I.R.C. 1954. Eugene Vassallo, 23 T.C. 656 (1955), distinguished. Meyer J. Safra, 30 T.C. 1026 (1958), not followed.

1Opinion of the Court

John W. Amos, Petitioner, v. Commissioner of Internal Revenue, Respondent

Amos v. Commissioner

Docket No. 4476-62

United States Tax Court

43 T.C. 50; 1964 U.S. Tax Ct. LEXIS 28;

October 21, 1964, Filed October 21, 1964, Filed

An appropriate order and decision will be entered for the respondent.

Held, petitioner's conviction for willful attempted evasion of income taxes for the years 1955 through 1958 in violation of section 7201, I.R.C. 1954, necessarily carries with it the ultimate factual determination that a part of the resulting deficiencies for those years was "due to fraud" within the purview…

Also in this document: Concurrence; Dissent · Withey; Dissent · Pierce; Dissent · Drennen.

2Cases cited30 opinions

  1. Commissioner v. SunnenSupreme Court of the United States · 1948
  2. Cromwell v. County of SacSupreme Court of the United States · 1877
  3. Spies v. United StatesSupreme Court of the United States · 1943
  4. Helvering v. MitchellSupreme Court of the United States · 1938
  5. Helvering v. HallockSupreme Court of the United States · 1940

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