Mitchell, Herbert v. Cmsnr IRS

How courts have described this case

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

• “Subsection (f) has no statutory antecedent as a stand alone provision, but has roots in the equity test of former subparagraph 6013(e)(1)(D) carried forward into subparagraph 6015(b)(1)(D).”
• “Subsection (0 has no statutory antecedent as a stand alone provision, but has roots in the equity test of former subparagraph 6015(b)(1)(D) carried forward into subparagraph 6015(b)(1)(D).”
• “Ignorance of the law, standing alone, . . . is not a defense under any test.”
• taxpayer’s ignorance of the tax consequences of income received is no defense to the obligation to pay taxes
• “Subsection (0 has no statutory antecedent as a stand alone provision, but has roots in the equity test of former subparagraph 6015(b)(1)(D) carried forward into subparagraph 6015(b)(1)(D).”
• cases deciding whether a taxpayer was entitled to equitable relief under former section 6013(e)(1)(D) are helpful in deciding whether a taxpayer is entitled to relief under section 6015(f)

Source: CourtListener parenthetical corpus (CC0).