Legal Opinion

Bevan v. Commissioner

United States Tax Court

Decided December 13, 1971No. Docket No. 4588-69UnpublishedCited by 1 opinion

Reconstruction of income: Understatement: Fraud: False & fraudulent return: Statute of limitations. - 1. Adjustments of gross income and business expense deductions for 1962, 1963, and 1964 are redetermined. 2. The underpayments of tax for 1962, 1963, and 1964 were not "due to fraud."

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Reconstruction of income: Understatement: Fraud: False & fraudulent return: Statute of limitations. - 1. Adjustments of gross income and business expense deductions for 1962, 1963, and 1964 are redetermined. 2. The underpayments of tax for 1962, 1963, and 1964 were not "due to fraud." Sec. 6653(b), I.R.C. 1954. 3. Petitioners' income tax return for 1965 was not "false or fraudulent," sec. 6501 (c)(1), I.R.C. 1954; the assessment of a deficiency for that year is barred by the statute of limitations.

1Opinion of the Court

Walter E. Bevan and Irene Bevan v. Commissioner.

Bevan v. Commissioner

Docket No. 4588-69.

United States Tax Court

T.C. Memo 1971-312; 1971 Tax Ct. Memo LEXIS 19; 30 T.C.M. (CCH) 1337; T.C.M. (RIA) 71312;

December 13, 1971, Filed

Reconstruction of income: Understatement: Fraud: False & fraudulent return: Statute of limitations. - 1. Adjustments of gross income and business expense deductions for 1962, 1963, and 1964 are redetermined.

2. The underpayments of tax for 1962, 1963, and 1964 were not "due to fraud." Sec. 6653(b), I.R.C. 1954.

3. Petitioners' income tax return for 1965 was not "false or…

2Cases cited8 opinions

  1. Bolen Webb and Cornelia Webb v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1968
  2. George Schwarzkopf v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1957
  3. Boyett Et Ux. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1953
  4. Miller v. CommissionerUnited States Tax Court · 1969
  5. United States v. CasertaCourt of Appeals for the Third Circuit · 1952

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

3Cited by1 opinion

  1. Walter E. Bevan and Irene Bevan v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1973

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