Johnson v. Commissioner
United States Tax Court
1. Held, that the decision redetermining income tax deficiency in a former proceeding between the same parties for prior taxable years is not res judicata of the present proceeding, since the causes of action of the two proceedings are different and the decision in the former did not determine the issues of the present proceeding. 2. Held, (a) that rents, issues, and profits from lands in Texas, whether the separate property of petitioner or community property, fall into the…
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1. Held, that the decision redetermining income tax deficiency in a former proceeding between the same parties for prior taxable years is not res judicata of the present proceeding, since the causes of action of the two proceedings are different and the decision in the former did not determine the issues of the present proceeding. 2. Held, (a) that rents, issues, and profits from lands in Texas, whether the separate property of petitioner or community property, fall into the community; (b) that the ownership of rents, issues, and profits from lands in New Mexico is of the same character as…
1Opinion of the Court
W. D. Johnson, Petitioner, v. Commissioner of Internal Revenue, Respondent
Johnson v. Commissioner
Docket No. 106725
United States Tax Court
1 T.C. 1041; 1943 U.S. Tax Ct. LEXIS 172;
May 4, 1943, Promulgated
Decision will be entered under Rule 50.
1. Held, that the decision redetermining income tax deficiency in a former proceeding between the same parties for prior taxable years is not res judicata of the present proceeding, since the causes of action of the two proceedings are different and the decision in the former did not determine the issues of the present proceeding.
2. Held, (a) that rents,…
2Cases cited15 opinions
- Cromwell v. County of SacSupreme Court of the United States · 1877
- Tait v. Western Maryland Railway Co.Supreme Court of the United States · 1933
- McCutchen v. PurintonTexas Supreme Court · 1892
- Logan v. LoganCourt of Appeals of Texas · 1937
- Johnson v. CommissionerUnited States Tax Court · 1943
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