Don Casey Co. v. Commissioner
United States Tax Court
The Commissioner determined that the DC Co. owed certain deficiencies and that it was liable for the addition to tax for fraud under sec. 6653(b), I.R.C. 1954. The parties agreed that the statute of limitations had run unless the Commissioner proved fraud. After the trial, the Court rendered a bench opinion announcing that the Commissioner had failed to prove fraud and that therefore the company was not liable for the deficiency.
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The Commissioner determined that the DC Co. owed certain deficiencies and that it was liable for the addition to tax for fraud under sec. 6653(b), I.R.C. 1954. The parties agreed that the statute of limitations had run unless the Commissioner proved fraud. After the trial, the Court rendered a bench opinion announcing that the Commissioner had failed to prove fraud and that therefore the company was not liable for the deficiency. Thereafter, the company filed a motion for reimbursement of its litigation costs under sec. 7430, I.R.C. 1954. Held, in pursuing the litigation in this Court, the…
1Opinion of the Court
Don Casey Co., Inc.; Charles Don Casey, Sole Shareholder of Don Casey Co., Inc., Petitioner v. Commissioner of Internal Revenue, Respondent
Don Casey Co. v. Commissioner
Docket No. 42107-84
United States Tax Court
87 T.C. 847; 1986 U.S. Tax Ct. LEXIS 29; 87 T.C. No. 54;
October 28, 1986, Filed
The petitioner's motion for costs will be granted and decision will be entered for the petitioner.
The Commissioner determined that the DC Co. owed certain deficiencies and that it was liable for the addition to tax for fraud under sec. 6653(b), I.R.C. 1954. The parties agreed that the statute of limitations…
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