Legal Opinion
Alfonzo L. Dowell and Vivian T. Dowell v. Commissioner of Internal Revenue
Court of Appeals for the Tenth Circuit
Decided February 11, 1980No. 78-1341PublishedCited by 34 opinions
1Opinion of the Court
SETH, Chief Judge.
This is an appeal from a ruling of the United States Tax Court against appellants. Dowell v. Commissioner, 68 T.C. 646. The facts are undisputed. Taxpayers filed fraudulent income tax returns for calendar years 1963, 1964, 1965, and 1966. On September 13, 1968, taxpayers filed nonfraudulent amended returns for 1965 and 1966, and on November 25, 1968 they filed non-fraudulent amended returns for 1963 and 1964.
The Government used the amended returns in its fraud investigation, and also used them to convict taxpayers of willfully filing fraudulent returns for 1963-1966. United…
2Cases cited10 opinions
- Zellerbach Paper Co. v. HelveringSupreme Court of the United States · 1934
- Colony, Inc. v. CommissionerSupreme Court of the United States · 1958
- Roland J. Kalb v. United States of America, and Third-Party v.jerome L. Herold, Third-PartyCourt of Appeals for the Second Circuit · 1974
- Bennett v. CommissionerUnited States Tax Court · 1958
- Houston v. CommissionerUnited States Tax Court · 1962
5 more not listed; retrieve them via the Exa API.
3Cited by34 opinions
- Badaracco v. CommissionerSupreme Court of the United States · 1984
- Espinoza v. CommissionerUnited States Tax Court · 1982
- United States v. BotefuhrCourt of Appeals for the Tenth Circuit · 2002
- Riland v. CommissionerUnited States Tax Court · 1982
- The Neptune Mutual Association, Ltd. Of Bermuda v. The United States, Defendant/cross-AppellantCourt of Appeals for the Federal Circuit · 1988
29 more not listed; retrieve them via the Exa API.