Legal Opinion
Joseph N. Romm and Helen K. Romm, His Wife v. Commissioner of Internal Revenue
Court of Appeals for the Fourth Circuit
Decided May 27, 1957No. 7366PublishedCited by 26 opinions
1Opinion of the Court
SOBELOFF, Circuit Judge.
This is a petition to review the decision of the Tax Court holding the petitioner liable for income tax deficiencies and fraud penalties for the years 1942-46.
The year 1946 is open for deficiency assessment by the taxpayer’s waiver of limitations, but the years 1942-45 are closed by limitations, unless the taxpayer filed fraudulent returns with the intent to evade taxes in those years. Internal Revenue Code of 1939, Section 276(a), 26 U.S.C. (1952 ed.) Section 276 (a). The Tax Court found that the returns for those years were fraudulent and not closed to assessment.
Defi…
2Cases cited9 opinions
- Holland v. United StatesSupreme Court of the United States · 1955
- Rogers v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1940
- Morris Lipsitz, and Morris Lipsitz and Helen Lipsitz v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1955
- George M. Still, Inc. v. CommissionerUnited States Tax Court · 1953
- Geo. M. Still, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1955
4 more not listed; retrieve them via the Exa API.
3Cited by26 opinions
- Milford R. Baumgardner and Pearl E. Baumgardner v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1957
- William Levinson and William Levinson, Assignee of F.M.P. Corporation, Formerly Known as Fairmount Motor Products Co., Inc. v. United StatesCourt of Appeals for the Third Circuit · 1974
- Stewart v. CommissionerUnited States Tax Court · 1976
- Parsons v. CommissionerUnited States Tax Court · 1964
- Stanley v. CommissionerUnited States Tax Court · 1983
21 more not listed; retrieve them via the Exa API.