Donald G. Smith v. Commissioner of Internal Revenue

U.S. Court of Appeals, Sixth Circuit · Decided 1991-04-22

Cited by 125 later decision(s) in our corpus · see the citation network in Lexace

From the opinion

SUHRHEINRICH, Circuit Judge. Petitioner appeals from the tax court’s order denying his motion to vacate a default judgment granting the deficiency amount and fraud penalties. For the reasons stated below, the decision of the tax court is AFFIRMED. I. On April 15, 1976, the Commissioner of Internal Revenue (“Commissioner” or “respondent”) sent a statutory notice of deficiency to petitioner…

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