Legal Opinion
Hoefle v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
Decided September 16, 1940No. 8232PublishedCited by 72 opinions
1Opinion of the Court
ARANT, Circuit judge.
The Commissioner of Internal Revenue asserted a deficiency in petitioner's income tax for the year 1931, and also assessed penalties for late filing and for failure, with intent to defraud the United States, fully to report income. The Board of Tax Appeals sustained the Commissioner in his holding that certain unidentified deposits constituted income, his denial of certain deductions claimed for bad debts, and his assessments of' penalties.
For some time prior to 1931, petitioner was in the employ of W. C. Rands, Inc., a company engaged in the investment brokerage business…
2Cases cited5 opinions
- Helvering v. MitchellSupreme Court of the United States · 1938
- Helvering v. F. & R. Lazarus & Co.Supreme Court of the United States · 1939
- Palmer v. CommissionerSupreme Court of the United States · 1937
- Sabatini v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1938
- Marshall v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1932
3Cited by72 opinions
- Estate of Mason v. CommissionerUnited States Tax Court · 1975
- Harper v. CommissionerUnited States Tax Court · 1970
- Boyett Et Ux. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1953
- William O'Dwyer and Sloan O'Dwyer v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1959
- John F. Kurnick and Celia Kurnick v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1956
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