Legal Opinion
Joseph P. Caulfield v. Commissioner of Internal Revenue
Court of Appeals for the Eighth Circuit
Decided October 19, 1994No. 93-4054 and 93-4057PublishedCited by 31 opinions
1Opinion of the Court
LOKEN, Circuit Judge.
Using the bank-deposits-plus-cash-expenditures method to reconstruct taxable income, the Commissioner of Internal Revenue determined that Joseph Caulfield, a public insurance adjuster, underpaid his 1982 and 1984 federal income taxes. The Commissioner assessed tax deficiencies for those years, including negligence and underpayment additions. The Tax Court upheld the Commissioner in all respects. See Caulfield v. Commissioner, 66 T.C.M. (CCH) 710, 1993 WL 347344 (1993). Caulfield challenges the reconstruction of his taxable income and the addition of negligence and…
2Cases cited20 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Pallottini v. CommissionerUnited States Tax Court · 1988
- Parks v. CommissionerUnited States Tax Court · 1990
- David E. Heasley and Kathleen Heasley v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1990
- George Schwarzkopf v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1957
15 more not listed; retrieve them via the Exa API.
3Cited by31 opinions
- Donald R. Ferguson v. United States v. Richard Musal, Third Party Nicholas P. Miller, Third PartyCourt of Appeals for the Third Circuit · 2007
- Estate of Robert G. Kluener, Donald E. Hathaway, Co-Executor, Charlotte J. Kluener v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1998
- Douglas Page v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1995
- David D. Parrish v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1999
- Alpha I, L.P. v. United StatesUnited States Court of Federal Claims · 2010
26 more not listed; retrieve them via the Exa API.