Legal Opinion
Archie Dale Carson v. United States
Court of Appeals for the Fifth Circuit
Decided October 11, 1977No. 75-3262PublishedCited by 98 opinions
1Opinion of the Court
GOLDBERG, Circuit Judge:
Archie Dale Carson (taxpayer), appeals from the district court’s rejection of his challenge to two excise tax assessments based on his alleged wagering activities during the fall and winter months of 1970-71 and 1971-72. He contends that those assessments, based on projections from his records of the bets he accepted during one week in January 1972, are arbitrary and excessive.
Disposing of this appeal requires examination of taxpayer’s burden of proof and the significance of his destroying most of his wagering records other than those on which the government…
2Cases cited12 opinions
- United States v. JanisSupreme Court of the United States · 1976
- Bull v. United StatesSupreme Court of the United States · 1935
- Bolen Webb and Cornelia Webb v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1968
- Andrew Gerardo v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1977
- Joseph P. Lucia v. United States of AmericaCourt of Appeals for the Fifth Circuit · 1973
7 more not listed; retrieve them via the Exa API.
3Cited by98 opinions
- Johnny Weimerskirch v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1979
- Jackson v. CommissionerUnited States Tax Court · 1979
- Raul Llorente v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1981
- Ramon Portillo and Dolores Portillo v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1991
- Nelson M. Blohm and Joann M. Blohm v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1993
93 more not listed; retrieve them via the Exa API.