Legal Opinion

Allnutt v. Commissioner, IRS

Court of Appeals for the Fourth Circuit

Decided April 23, 2008No. 06-1477PublishedCited by 17 opinions

1Opinion of the Court

Affirmed by published opinion. Judge DUNCAN wrote the opinion, in which Senior Judge HAMILTON and Judge OSTEEN joined.

OPINION

DUNCAN, Circuit Judge:

Appellant Fred W. Allnutt, Sr. (“All-nutt”) failed to timely file his federal income tax returns for the years 1981 through 1995. In 1997, after being acquitted of certain tax crimes, Allnutt prepared the past returns and submitted them to the Internal Revenue Service (“IRS”). In 2000, the IRS issued a notice of deficiency for those tax years, indicating that he underpaid by nearly two million dollars.

Allnutt subsequently filed a petition before…

2Cases cited7 opinions

  1. Badaracco v. CommissionerSupreme Court of the United States · 1984
  2. Florsheim Brothers Drygoods Co. v. United StatesSupreme Court of the United States · 1930
  3. E. I. Dupont De Nemours & Co. v. DavisSupreme Court of the United States · 1924
  4. Lucas v. Pilliod Lumber Co.Supreme Court of the United States · 1930
  5. Helvering v. CampbellCourt of Appeals for the Fourth Circuit · 1944

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3Cited by17 opinions

  1. Commissioner of IRS v. Estate of Travis L. SandersCourt of Appeals for the Eleventh Circuit · 2016
  2. Appleton v. Comm'rUnited States Tax Court · 2013
  3. Sanders v. Comm'rUnited States Tax Court · 2015
  4. Judith Coffey v. CIRCourt of Appeals for the Eighth Circuit · 2021
  5. Seaview Trading, LLC, Agk Inve v. CirCourt of Appeals for the Ninth Circuit · 2023

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