Legal Opinion
Jennie Allen v. Commissioner of Internal Revenue
Court of Appeals for the Fifth Circuit
Decided June 11, 1975No. 74-2884PublishedCited by 59 opinions
1Opinion of the Court
LEWIS R. MORGAN, Circuit Judge:
Taxpayer, Jennie Allen, appeals from a decision by the Tax Court, 61 T.C. 125 (1974), finding deficiencies due in federal income tax for 1960 and 1961. We reverse the Tax Court’s holding that Mrs. Allen is not entitled to the protection of section 6013(e), Internal Revenue Code of 1954, 26 U.S.C. § 6013(e), the “innocent spouse” statute, for tax year 1960, and affirm its holding that certain items of income for the tax years in question were “income from property,” within the meaning of section 6013(e)(2)(A). We remand for further fact finding as to whether…
2Cases cited8 opinions
- Stone v. CommissionerUnited States Tax Court · 1971
- Helvering v. BlissSupreme Court of the United States · 1934
- Bettye A. Sanders v. United StatesCourt of Appeals for the Fifth Circuit · 1975
- Sonnenborn v. CommissionerUnited States Tax Court · 1971
- Allen v. CommissionerUnited States Tax Court · 1973
3 more not listed; retrieve them via the Exa API.
3Cited by59 opinions
- Purcell v. CommissionerUnited States Tax Court · 1986
- Patricia A. Price v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1989
- James A. Guth, and Arlys M. Guth v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1990
- Lucille E. Kistner F/k/a/ Lucille E. Weasel v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1994
- Guth v. CommissionerUnited States Tax Court · 1987
54 more not listed; retrieve them via the Exa API.