Legal Opinion

Morris v. Commissioner

United States Tax Court

Decided July 16, 1958No. Docket No. 42101PublishedCited by 43 opinions

1. Held, petition dismissed for lack of prosecution, and deficiencies and additions to tax under section 294 (d) (1) (A) and (d) (2), I. R. C. 1939, found as set forth in the notice of deficiency. 2. Held, respondent's burden of proof as to fraud issue is adequately supported by facts alleged in the answer and deemed admitted as a result of Tax Court's order under Rule 18, entered after notice and default by petitioner.

1Opinion of the Court

OPINION.

Van Fossan, Judge:

The Commissioner determined deficiencies in income tax and additions to tax under sections 293 (b), 294 (d) (1) (A), and 294 (d) (2) of the Internal Revenue Code of 1989, against the petitioner as follows:

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These deficiencies and additions to tax were made the subject of a jeopardy assessment.

Petitioner, Louis Morris, is a resident of Osceola, Indiana. He filed his income tax returns for the years here involved with the then collector of internal revenue for the district of Indiana.

Petitioner’s income tax returns for each of the years 1946 through 1950…

2Cited by43 opinions

  1. Gilday v. CommissionerUnited States Tax Court · 1974
  2. Gordon v. CommissionerUnited States Tax Court · 1980
  3. Moran v. CommissionerUnited States Tax Court · 1966
  4. Simmons v. CommissionerUnited States Tax Court · 1980
  5. Watson v. CommissionerUnited States Tax Court · 1964

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