Opinion · United States Tax Court

Petterson v. Commissioner

19 T.C. 486

Type
Opinion
Court
United States Tax Court
Jurisdiction
Federal
Date
1952-12-18
Topic
general

OPINION. Opper, Judge: A deficiency for 1947 in addition to tax on account' of fraud in the amount of $4,475.32 is the sole controversy. There is no question as to the existence of fraud and the sole issue is one of law. It is whether the amount of the 50 per cent fraud penalty is to be computed on the original deficiency or on the smaller sum admittedly reduced by a net loss carry-back from a subsequent year. All of the facts have been stipulated and are hereby found accordingly.

Citator

UpLaw has not yet analyzed Petterson v. Commissioner. The absence of a flag is not a finding that it is good law.

Cited by
33 opinions