Legal Opinion
Charles A. Polizzi and Angela Polizzi v. Commissioner of Internal Revenue, Charles A. Polizzi v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
Decided April 2, 1959No. 13585_1PublishedCited by 16 opinions
1Opinion of the Court
SHACKELFORD MILLER, JR., Circuit Judge.
The petitioner Charles A. Polizzi filed timely individual income tax returns for the years 1944 and 1945. He did not file a return for the year 1947. He and his wife, Angela Polizzi, filed timely joint returns for the years 1949 and 1950. In a review of deficiencies determined by the Commissioner for each of the years referred to, the Tax Court approved deficiencies in income tax for the years 1944, 1945, 1947, 1949 and 1950, additions to the tax on account of fraud for each of the years except 1950, an addition to the tax for the year 1947 for failure…
2Cases cited17 opinions
- Holland v. United StatesSupreme Court of the United States · 1955
- Helvering v. TaylorSupreme Court of the United States · 1935
- United States v. S. S. White Dental Manufacturing Co.Supreme Court of the United States · 1927
- Durkee v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1947
- United States v. CasertaCourt of Appeals for the Third Circuit · 1952
12 more not listed; retrieve them via the Exa API.
3Cited by16 opinions
- United Aniline Company v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1963
- Paul v. Weir and Margaret G. Weir v. Commissioner of Internal Revenue, Paul v. Weir v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1960
- Steadman v. Comm'rUnited States Tax Court · 1968
- Howard Ratliff and Gloria Ratliff v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1989
- Mazzoni v. CommissionerUnited States Tax Court · 1970
11 more not listed; retrieve them via the Exa API.