Legal Opinion

Commissioner of Internal Revenue v. Peter Licavoli

Court of Appeals for the Sixth Circuit

Decided February 14, 1958No. 13135_1PublishedCited by 29 opinions

1Opinion of the Court

SHACKELFORD MILLER, Jr., Circuit Judge.

The Commissioner seeks review of the Decision of the Tax Court resulting from a ruling in a proceeding by the respondent taxpayer to review a deficiency assessment, which in practical effect struck from the record the Commissioner’s answer, because of his failure or refusal to comply with the Court’s order to file an amended answer making a more complete statement of his defense. Following the ruling, the Tax Court rendered its Decision of no deficiency. The nature of the issue requires a somewhat detailed review of the pleadings.

The taxpayer filed this…

2Cases cited14 opinions

  1. Bessie Lasky and Jesse L. Lasky v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1956
  2. Commissioner of Internal Revenue v. Erie Forge Co.Court of Appeals for the Third Circuit · 1948
  3. Joseph Starr v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1955
  4. Mutual Life Ins. Co. of New York v. KrejciCourt of Appeals for the Seventh Circuit · 1941
  5. Charles A. Polizzi v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1957

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

3Cited by29 opinions

  1. Ellis Campbell, Jr., District Director of Internal Revenue v. J. M. Eastland and Montez EastlandCourt of Appeals for the Fifth Circuit · 1962
  2. In Re Beef Industry Antitrust Litigation, Mdl Docket No. 248. Pony Creek Cattle Co., Inc., Musselman Ranch Co., Etc., Plaintiffs-Intervenors-Appellants v. The Great Atlantic & Pacific Tea Co., R. Dirk Agee v. Safeway Stores, Inc., Meat Price Investigators Association, Etc. v. Safeway Stores, Inc., Richard S. Lowe v. Safeway Stores, Inc., A. L. Black v. Albertson's, Inc., (Two Cases). Chaparral Cattle Corp. v. Safeway Stores, Inc., Burke Petersen v. Safeway Stores, Inc., Ronald Becker, on Behalf of Themselves and All Other Persons Similarlysituated v. Safeway Stores, Inc., John O. Varian v. Safeway Stores, Inc., Meat Price Investigators Association v. Safeway Stores, Inc., Etc., Little Ranch Co., Inc. v. The National Association of Food Chains, Etc., Ronald Becker, on Behalf of Themselves and All Other Persons Similarlysituated v. Safeway Stores, Inc., Etc.Court of Appeals for the Fifth Circuit · 1979
  3. John Factor v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1960
  4. Donald G. Smith v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1991
  5. Klein v. CommissionerUnited States Tax Court · 1965

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

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