Howard B. Quinn and Charlotte J. Quinn v. Commissioner of Internal Revenue

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• holding that no loan transaction occurred and embezzled funds were includable in income where the savings and loan could not make a loan to the taxpayer under State law
• holding, in an omission of income case, that “[t]he knowledge contemplated by [§ 6013(e)(1)(C)] is not knowledge of the tax consequences of a transaction but rather knowledge of the transaction itself”
• “The knowledge contemplated by the statute is not knowledge of the tax consequences of a transaction but rather knowledge of the transaction itself.”
• “when a section of a statute is declared void, the statute cannot be given effect as though the legislature had not enacted the conditions limiting its operation.” Id. at 626
• court views as significant the spouse's degree of participation in business affairs or bookkeeping

Source: CourtListener parenthetical corpus (CC0).