Corbett v. Commissioner
United States Tax Court
Held, statutory notice of deficiency in D's 1945 income tax for addition to tax under section 294(d)(1)(B), I.R.C. 1939, otherwise barred by limitations, was timely since D's return had falsely claimed a prepayment credit of estimated tax and was false and fraudulent with intent to evade tax. Held, further, fraud not established in respect of companion deficiency determined against D's wife, which was therefore barred.
1Opinion of the Court
Donald G. Corbett, Petitioner, v. Commissioner of Internal Revenue, Respondent; Donald G. Corbett, as Sole Devisee and Legatee Under the Will of Georgia C. Corbett, Deceased, Petitioner, v. Commissioner of Internal Revenue, Respondent
Corbett v. Commissioner
Docket Nos. 71992, 71993
United States Tax Court
41 T.C. 96; 1963 U.S. Tax Ct. LEXIS 31;
October 25, 1963, Filed
Decisions will be entered in accordance with the foregoing opinion.
Held, statutory notice of deficiency in D's 1945 income tax for addition to tax under section 294(d)(1)(B), I.R.C. 1939, otherwise barred by limitations, was timely…
2Cases cited5 opinions
- Corbett v. FrankCourt of Appeals for the Ninth Circuit · 1961
- Simmons v. CommissionerUnited States Tax Court · 1956
- Estate of Roe v. CommissionerUnited States Tax Court · 1961
- Franklin v. CommissionerUnited States Board of Tax Appeals · 1936
- Corbett v. CommissionerUnited States Tax Court · 1963