Wright v. Commissioner
United States Tax Court
84 T.C. 636 (1985)
- Written by Steven Pacht, JD
Facts
In 1975, John Wright (plaintiff) began running his family’s farm upon his father’s death. John had no prior business or farming experience, nor was he trained in bookkeeping, accounting, or business management. John and his wife, Susan Wright, filed joint federal income tax returns for 1976, 1977, and 1978 with the assistance of an accountant who was skilled in farming bookkeeping. In June 1982, John pleaded guilty to willfully and knowingly making and subscribing to a false income tax return in violation of Internal Revenue Code (code) § 7206(1). Specifically, John pleaded guilty to verifying under penalty of perjury that the Wrights’ returns were materially true and correct despite knowing and believing otherwise. In September 1983, the Internal Revenue Service (IRS) issued a deficiency notice against the Wrights. The Wrights sued the IRS commissioner (defendant) in the United States Tax Court challenging the deficiency determination. The commissioner moved for partial summary judgment, arguing that John’s criminal conviction collaterally estopped John from contesting that he engaged in fraud within the meaning of the code’s fraud-penalty provision (code § 6653(b)).
Rule of Law
Issue
Holding and Reasoning (Tannenwald, J.)
What to do next…
Here's why 899,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 47,000 briefs, keyed to 994 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.
