Rodney v. Comm'r
United States Tax Court
Held: 1. Because of his criminal conviction of willful attempt to evade income tax for the years 1959 through 1962, petitioner Henry M. Rodney is collaterally estopped to deny that the joint income tax returns that he filed with his wife for the years 1959 through 1962 were false and fraudulent or that a part of the underpayment, if any, in tax for those years is due to fraud with intent to evade tax.
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Held: 1. Because of his criminal conviction of willful attempt to evade income tax for the years 1959 through 1962, petitioner Henry M. Rodney is collaterally estopped to deny that the joint income tax returns that he filed with his wife for the years 1959 through 1962 were false and fraudulent or that a part of the underpayment, if any, in tax for those years is due to fraud with intent to evade tax. Therefore, the assessment and collection of any deficiency in tax for none of those years from Henry M. Rodney is barred by the statute of limitations and he is liable for the addition to tax…
1Opinion of the Court
Henry M. Rodney and Lucille H. Rodney, Petitioners v. Commissioner of Internal Revenue, Respondent
Rodney v. Comm'r
Docket Nos. 2788-64, 102-68
United States Tax Court
53 T.C. 287; 1969 U.S. Tax Ct. LEXIS 18;
November 25, 1969, Filed
Decisions will be entered under Rule 50.
Held: 1. Because of his criminal conviction of willful attempt to evade income tax for the years 1959 through 1962, petitioner Henry M. Rodney is collaterally estopped to deny that the joint income tax returns that he filed with his wife for the years 1959 through 1962 were false and fraudulent or that a part of the underpayment,…
Also in this document: Concurrence; Concurring in part, dissenting in part; Dissent.
2Cases cited60 opinions
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Helvering v. MitchellSupreme Court of the United States · 1938
- 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
- Hanover Bank v. CommissionerSupreme Court of the United States · 1962
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