Legal Opinion

Jerry W. Counts and Rae A. Counts v. Commissioner of Internal Revenue

Court of Appeals for the Eleventh Circuit

Decided September 5, 1985No. 85-3073PublishedCited by 17 opinions

Non-Argument Calendar.

1Per curiam

The Commissioner assessed a deficiency against the appellant taxpayers, Jerry W. and Rae A. Counts, for the taxable year 1980. The Counts had purported to file a joint return, but they altered their Form 1040 in several respects. They modified line 22 to read “total receipts” instead of “total income”; they entitled line 24 “nontaxable receipts” instead of “employee business expenses”; line 25 was entitled “(Eisner v. Macomber, 252 U.S. 189, 40 S.Ct. 189, 64 L.Ed. 521) etc. attached” instead of “payments to an IRA”; and they added to the jurat at the end of the form: “Signed involuntarily…

2Cases cited7 opinions

  1. Eisner v. MacOmberSupreme Court of the United States · 1920
  2. Eisner, Internal Revenue Collector v. MacOmberSupreme Court of the United States · 1919
  3. Commissioner v. Lane-Wells Co.Supreme Court of the United States · 1944
  4. Thomas A. Moore, Sr. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1984
  5. Dorothy Olster v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Eleventh Circuit · 1985

2 more not listed; retrieve them via the Exa API.

3Cited by17 opinions

  1. Robert D. Beard v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1986
  2. Sloan v. CommissionerUnited States Tax Court · 1994
  3. Gordon R. Kartrude, Jr. v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1991
  4. In Re HahnUnited States Bankruptcy Court, M.D. Florida · 1996
  5. In Re TobiasUnited States Bankruptcy Court, M.D. Florida · 1996

12 more not listed; retrieve them via the Exa API.

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API