Legal Opinion

Commissioner of Internal Revenue v. Ray

Court of Appeals for the Seventh Circuit

Decided February 11, 1937No. 6014PublishedCited by 24 opinions

1Opinion of the Court

EVANS, Circuit Judge.

The Commissioner appeals from the Board’s award of a deficiency of $4,057.73 instead of $9,127.37 for the year 1928. Controversy arises over the Commissioner’s right to amend his claim to conform to the findings of the Board.

The Facts. In 1926, taxpayer received a note for $25,000 payable in a year, and in 1928, a piece of realty valued at $70,-000. The maker of the note and the grantor in the deed was a neighbor to whom taxpayer had frequently given advice. The Board determined, upon evidence which supported such a finding, that the property thus received was…

2Cases cited2 opinions

  1. Chicago Ry. Equipment Co. v. BlairCourt of Appeals for the Seventh Circuit · 1927
  2. Helvering v. Edison Securities CorporationCourt of Appeals for the Fourth Circuit · 1935

3Cited by24 opinions

  1. Robert A. Henningsen, and Cross and R.A. And Margaret Henningsen v. Commissioner of Internal Revenue, AndCourt of Appeals for the Fourth Circuit · 1957
  2. Law v. CommissionerUnited States Tax Court · 1985
  3. W. H. Armston Co., Inc. v. Commissioner of Internal Revenue. Armston v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1951
  4. Paccar, Inc. And Subsidiaries v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1988
  5. Koufman v. CommissionerUnited States Tax Court · 1977

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