· 1/3/1977
Casper W. Marsellus v. Commissioner of Internal Revenue
Citations
- 544 F.2d 883
- 39 A.F.T.R.2d (RIA) 595
- 1977 U.S. App. LEXIS 10724
How courts have described this case
Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.
- holding that a finding of fraud may be reversed only for clear error, but that the finding must be judged in view of the “clear and convincing” burden of proof
- stating that while the clearly erroneous standard applies to the Tax Court’s finding of fraud, “we must judge the Tax Court’s findings in light of the government’s burden of proving fraud by ‘clear and convincing’ evidence”
- stating that while the clearly erroneous standard applies to the Tax Court’s finding of fraud, “we must judge the Tax Court’s findings in light of the government’s burden of proving fraud by ‘clear and convincing’ evidence”
- stating that while the clearly erroneous standard applies to the Tax Court’s finding of fraud, “we must judge the Tax Court’s findings in light of the government’s burden of proving fraud by ‘clear and convincing’ evidence”
- “The issue of fraud is a factual one. Thus, we may reverse the Tax Court’s finding of fraud only if we find that it was ‘clearly erroneous.’ At the same time, we must judge the Tax Court’s findings in light of the government’s burden of proving (continued...
- “The issue of fraud is a factual one. Thus, we may reverse the Tax Court’s finding of fraud only if we find that it was ‘clearly erroneous.’ At the same time, we must judge the Tax Court’s findings in light of the government’s burden of proving section 6653(a
Source: CourtListener parenthetical corpus (CC0).
Judges: Wisdom, Gee, Tjoflat
Read full opinion on CourtListenerSourced from CourtListener / Free Law Project (CC0).
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