Legal Opinion

Humphreys v. Commissioner of Internal Revenue

Court of Appeals for the Seventh Circuit

Decided January 28, 1942No. 7700PublishedCited by 27 opinions

1Opinion of the Court

KERNER, Circuit Judge.

Petitioner asks us to review an order of the Board of Tax Appeals sustaining a deficiency determination for the years 1930, 1931, and 1932, 25% penalty for 1930 and 50% fraud penalty for all three years, on the ground that petitioner had not included $10,000 protection payments received from dry cleaners in 1930, $5,000 received as a proprietary interest in the Drexel Cleaners in 1931, bank deposits in the name of M. L. Brunswick totaling $29,332.82 for 1931 and $50,114.29 for 1932, and .$50,000 received as ransom money in 1931.

Concerning the $50,000 ransom payment in…

2Cases cited4 opinions

  1. Quock Ting v. United StatesSupreme Court of the United States · 1891
  2. Capone v. United StatesCourt of Appeals for the Seventh Circuit · 1931
  3. National City Bank of New York v. HelveringCourt of Appeals for the Second Circuit · 1938
  4. Staudenmaier v. JohnsonCourt of Appeals for the Seventh Circuit · 1941

3Cited by27 opinions

  1. Rutkin v. United StatesSupreme Court of the United States · 1952
  2. Halle v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1949
  3. Etta Potson Bodoglau, Administratrix of the Estate of Michael Potson, Deceased v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1956
  4. Lashells' Estate v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1953
  5. Nerem v. CommissionerUnited States Tax Court · 1963

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