SNELL ISLE, INC.

v.

COMMISSIONER OF INTERNAL REVENUE

Citator

Cited By

• Carter v. Carter, 264 F.2d 930 (5th Cir. 1959)
  …55.16.14 Where the case involves both a deficiency and a civil fraud penalty, each party has its own peculiar burden of proof.15 The result is, as we once pointed out, Snell Isle, Inc. v. Commissioner, 5 Cir., 1937, 90 F. 2d 481, certiorari denied 302 U.S. 734, 58 S.Ct. 120, 82 L.Ed. 568, the case may end in a standoff from the failure of each party to go ahead with his evidence.16 The taxpayer fails on the deficiency. The Government fails on the fraud penalty. Failure of the taxpayer to overcome the defi…
• United States v. Wendall Dale Brady, 425 F.2d 309 (8th Cir. 1970)
  …ld Electronics Corp. v. Westcoast Broadcasting Co., Inc., 341 F. 2d 653, 666 (9th Cir.), cert. denied, 382 U.S. 817, 86 S.Ct. 42, 15 L.Ed.2d 64 (1965); Snell Isle, Inc. v. Commissioner of Internal Revenue, 90 F. 2d 481, 482 (5th Cir.), cert. denied, 302 U.S. 734, 58 S.Ct. 120, 82 L.Ed. 568 (1937). The two questionable documents, along with the accompanying testimony, support the government’s case rather than contradict it. The inaccuracies in the documents, along with their hazy origin, tended to discredi…