MITCHELL

v.

COMMISSIONER OF INTERNAL REVENUE

Citator

Cited By

• Helvering v. Mitchell, 303 U.S. 391 (U.S. 1938)
  …y of 50 per cent, as barred by the prior acquittal of Mitchell in the criminal action.” 89 F. (2d) 873. Mitchell’s petition for certiorari to review so much of the judgment as upheld the assessment of the deficiency [*397] of $728,709.84 was denied. 302 U. S. 723. The Commissioner’s petition to review so much of the judgment as denied the 50 per centum in addition was granted, because of the importance in the administration of the revenue laws of the questions presented and alleged conflict in decisions. 302…
• Sherwood Bros., Inc. v. Dist. of Columbia, 113 F.2d 162 (D.C. Cir. 1940)
  …take the contrary view with respect to calculating the time for taking an appeal in federal judicial proceedings and for performing the acts necessary to an appeal,9 including Walker v. Hazen, 1937, 67 App.D.C. 188, 90 F. 2d 502, certiorari denied, 302 U.S. 723, 58 S.Ct. 44, 82 L.Ed. 559. The reasons given to support this view are varied and highly technical, some of them resting upon doubtful assumptions and contradictory premises.10 We do not consider it [*165] necessary to discuss them fully. It is suf…
• Est. of Anthony Geraci v. Commissioner OF Internal Revenue, 502 F.2d 1148 (6th Cir. 1974)
  …easonable cause and not due to willful neglect.” Absent such a showing by the taxpayer, imposition of the addition is mandatory. Cf. Fidelity & Columbia Trust Co. v. Commissioner [*1150] of Internal Revenue, 90 F. 2d 219, 223 (6th Cir.), cert. den., 302 U.S. 723, 58 S.Ct. 44, 82 L.Ed. 558 (1937). Although we are sympathetic with the plight of the executrix and would have preferred that the IRS have settled this matter at the administrative level and thereby avoided a harsh result, we cannot reverse the deci…