Acker v. Commissioner
United States Tax Court
Held, that each of the deficiencies here involved is due to fraud with intent to evade tax, and that the addition to the tax provided by section 293 (b) of the Internal Revenue Code (1939) has been properly applied; held, further, that the additions to the tax provided by section 291 (a) for failure to file returns, by section 294 (d) (1) (A) for failure to file declarations of estimated tax, and by section 294 (d) (2) for substantial underestimates of estimated tax have…
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Held, that each of the deficiencies here involved is due to fraud with intent to evade tax, and that the addition to the tax provided by section 293 (b) of the Internal Revenue Code (1939) has been properly applied; held, further, that the additions to the tax provided by section 291 (a) for failure to file returns, by section 294 (d) (1) (A) for failure to file declarations of estimated tax, and by section 294 (d) (2) for substantial underestimates of estimated tax have likewise been properly applied. Held, further, that the concurrent imposition of such additions to tax does not violate the…
1Opinion of the Court
OPINION.
PieRce, Judge:
Petitioner has not challenged the deficiencies. He disputes only the imposition of the several additions to- the tax; and even as to these, he waived in his petition any question respecting those imposed under section 291 (a) for failure to file returns, and he indicated at the hearing that he does, not seriously question those imposed under section 294 (d) (1) (A) for failure to file declarations of estimated tax. His principal objection is to the additions to the tax for fraud, under section 293 (b). But he further contends that, in any event, the additions under…
2Cases cited5 opinions
- Spies v. United StatesSupreme Court of the United States · 1943
- Helvering v. MitchellSupreme Court of the United States · 1938
- Fuller v. CommissionerUnited States Tax Court · 1953
- Ex Parte Tobias WatkinsSupreme Court of the United States · 1833
- Jones v. CommissionerUnited States Tax Court · 1956
3Cited by208 opinions
- Beaver v. CommissionerUnited States Tax Court · 1970
- Chris D. Stoltzfus and Irma H. Stoltzfus v. United StatesCourt of Appeals for the Third Circuit · 1968
- Grosshandler v. CommissionerUnited States Tax Court · 1980
- Harper v. CommissionerUnited States Tax Court · 1970
- Professional Services v. CommissionerUnited States Tax Court · 1982
203 more not listed; retrieve them via the Exa API.