Luther R. Patton 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.

• stating that “[t]he Commissioner bears the burden of proving fraud, which must be established by clear and convincing evidence”
• stating that “[t]he Commissioner bears the burden of proving fraud, which must be established by clear and convincing evidence”
• stating that “[t]he Commissioner bears the burden of proving fraud, which must be established by clear and convincing evidence”
• \ That Pattons' unreported income was from illegal activities is additional evidence of his tax evasive motive.\
• “The Commissioner bears the burden of proving fraud, which must be established by clear and convincing evidence.”
• “Clearly a tax court petition for redetermination is a ‘judicial proceeding’ within the meaning of 24 Rule 6(e)(3)([E])(i).”

Source: CourtListener parenthetical corpus (CC0).