Robinette v. Commissioner
United States Board of Tax Appeals
The taxpayer, now deceased, was a citizen of the United States and resided in the Philippine Islands during the years 1917 and 1918. For 1917 he filed a return of his income with the Philippine Government under the Revenue Act of 1916 and for 1918 he filed with that Government a return of his income under the Revenue Act of 1916, as amended by the Revenue Act of 1917. Most of his income for 1917 consisted of his distributive share of the income of a partnership.
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The taxpayer, now deceased, was a citizen of the United States and resided in the Philippine Islands during the years 1917 and 1918. For 1917 he filed a return of his income with the Philippine Government under the Revenue Act of 1916 and for 1918 he filed with that Government a return of his income under the Revenue Act of 1916, as amended by the Revenue Act of 1917. Most of his income for 1917 consisted of his distributive share of the income of a partnership. The respondent seeks to assess the tax against a transferee of a transferee of the taxpayer. Held, (1) the return which the taxpayer…
1Opinion of the Court
*1140OPINION.
Smith :
The respondent contends that the taxpayer, Charles C. Cole, formerly Charles C. Cohn, failed to file any income tax and excess profits tax returns as a citizen of the United States in 1917 and 1918 and has determined deficiencies for those years. He proposes to assess and collect the taxes from the petitioner as transferee of a transferee of the taxpayer, who is now deceased. The petitioner’s primary contention is that Charles C. Cole filed all the returns which he was required to file and paid all taxes which he was required to pay in the years in question. Second, the…
2Cases cited1 opinion
- Lawrence v. WardellCourt of Appeals for the Ninth Circuit · 1921
3Cited by5 opinions
- Helvering v. CampbellCourt of Appeals for the Fourth Circuit · 1944
- Pert v. CommissionerUnited States Tax Court · 1995
- Harvey M. Pert, Transferee v. CommissionerUnited States Tax Court · 1995
- Pert v. CommissionerUnited States Tax Court · 1995
- Robinette v. CommissionerUnited States Board of Tax Appeals · 1942