Petterson v. Commissioner
United States Tax Court
Original deficiency in income tax liability held proper base for computing 50 per cent fraud penalty, despite later reduction in tax deficiency due to loss carry-back from subsequent year. Nick v. Dunlap (C. A. 5), 185 F.2d 674, followed.
1Opinion of the Court
P. C. and Ethel Petterson, Petitioners, v. Commissioner of Internal Revenue, Respondent
Petterson v. Commissioner
Docket No. 35873
United States Tax Court
19 T.C. 486; 1952 U.S. Tax Ct. LEXIS 17;
December 18, 1952, Promulgated
Decision will be entered for the respondent.
Original deficiency in income tax liability held proper base for computing 50 per cent fraud penalty, despite later reduction in tax deficiency due to loss carry-back from subsequent year. Nick v. Dunlap (C. A. 5), 185 F.2d 674, followed.
Seymour Wells, C. P. A., for the petitioners.
R. G. Harless, Esq., for the respondent.
Opper,…
2Cases cited2 opinions
- Petterson v. CommissionerUnited States Tax Court · 1952
- Joseph L. Kamosky, and Joseph G. Kamosky, a Minor, by Joseph L. Kamosky, Guardian v. Owens-Illinois Glass CompanyCourt of Appeals for the Third Circuit · 1950