Legal Opinion
Broadhead v. Enochs
District Court, S.D. Mississippi
Decided December 23, 1959No. Civ. A. Nos. 724, 723, 675, 684, 679PublishedCited by 3 opinions
1Opinion of the Court
CLAYTON, District Judge.
This is a consolidation of five separate complaints filed by plaintiff to recover additional income taxes and penalties assessed for the years 1940, 1941, 1942, 1944, and 1945. Payment of these assessments was made June 26, 1952, and the complaints seek interest from the date of payment. At the time these assessments were made, the statute of limitations had been extended by written consent from plaintiff for the year 1941 only. For the other four years, the validity of the assessments depends entirely upon proof of fraud. Internal Revenue Code of 1939, § 276(a), 26…
2Cases cited20 opinions
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Helvering v. TaylorSupreme Court of the United States · 1935
- Tait v. Western Maryland Railway Co.Supreme Court of the United States · 1933
- United States v. International Building Co.Supreme Court of the United States · 1953
- B. B. Carter and Mrs. Tommie v. Carter v. Ellis Campbell, Jr., Director of Internal RevenueCourt of Appeals for the Fifth Circuit · 1959
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3Cited by3 opinions
- Estate of Wheeler v. Comm'rUnited States Tax Court · 1978
- B. B. Carter v. Ellis Campbell, Jr., District Director of Internal RevenueCourt of Appeals for the Fifth Circuit · 1960
- B. B. Carter v. Ellis Campbell, Jr., District Director of Internal RevenueCourt of Appeals for the Fifth Circuit · 1960