Legal Opinion
Estate of Albert D. Phillips, Deceased, Viola T. Chartrand, Formerly Viola T. Phillips, Administratrix v. Commissioner of Internal Revenue
Court of Appeals for the Fifth Circuit
Decided July 16, 1957No. 16235_1PublishedCited by 48 opinions
1Opinion of the Court
JOHN R. BROWN, Circuit Judge.
The Taxpayer’s appeal from adverse judgment of the Tax Court for a deficiency (but without fraud or statutory penalties) based upon the increase in net worth and non-deductible expenditure method presents the sole question whether there was an adequate showing of the cash on hand in the opening net worth statement as of January 1, 1947. A corollary to this is whether the presumptive correctness of the Commissioner’s deficiency is enough without more to allow the Tax Court to take the admitted cash on hand at the end of the period (November 17,1948) and dispense…
2Cases cited18 opinions
- Holland v. United StatesSupreme Court of the United States · 1955
- Helvering v. TaylorSupreme Court of the United States · 1935
- Bryan v. United StatesSupreme Court of the United States · 1950
- Fred M. Archer and Evie B. Archer v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1955
- Durkee v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1947
13 more not listed; retrieve them via the Exa API.
3Cited by48 opinions
- Frank J. Hradesky v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1976
- Condor Merritt v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1962
- B. B. Carter and Mrs. Tommie v. Carter v. Ellis Campbell, Jr., Director of Internal RevenueCourt of Appeals for the Fifth Circuit · 1959
- Thomas W. Banks v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1963
- Estate of Mazzoni v. CommissionerCourt of Appeals for the Third Circuit · 1971
43 more not listed; retrieve them via the Exa API.