Legal Opinion
John C. Raley v. Commissioner of Internal Revenue
Court of Appeals for the Third Circuit
Decided April 27, 1982No. 81-1484PublishedCited by 46 opinions
1Opinion of the Court
OPINION OF THE COURT
JAMES HUNTER, III, Circuit Judge:
The Internal Revenue Service (the “IRS”) assessed deficiencies in federal income taxes against appellant John C. Raley (the “taxpayer”) for the tax years 1972 through 1976. In addition, the IRS assessed Raley a penalty for his failure to pay an estimated tax pursuant to the Internal Revenue Code (“I.R.C.”) § 6654 and added a penalty in the amount of fifty percent of the deficiency for civil fraud pursuant to I.R.C. § 6653(b). The taxpayer contested the two penalty assessments in the United States Tax Court. 1
The tax court ruled that the…
2Cases cited4 opinions
- Chris D. Stoltzfus and Irma H. Stoltzfus v. United StatesCourt of Appeals for the Third Circuit · 1968
- Frank J. Valetti and Sarah J. Valetti v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1958
- Anthony Agnellino and Florence Agnellino v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1962
- Joseph A. Cirillo and Martha R. Cirillo v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. Joseph A. Cirillo and Martha R. CirilloCourt of Appeals for the Third Circuit · 1963
3Cited by46 opinions
- Rowlee v. CommissionerUnited States Tax Court · 1983
- Hebrank v. CommissionerUnited States Tax Court · 1983
- Joseph Edelson and Harriet Edelson v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1987
- Lucian T. Zell, II v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1985
- Anastasato v. CommissionerCourt of Appeals for the Third Circuit · 1986
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