Badaracco v. Commissioner

464 U.S. 386, 104 S. Ct. 756, 78 L. Ed. 2d 549 (1984)

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Badaracco v. Commissioner

United States Supreme Court
464 U.S. 386, 104 S. Ct. 756, 78 L. Ed. 2d 549 (1984)

Facts

Ernest Badaracco Sr. and Ernest Badaracco Jr. (plaintiffs) filed fraudulent tax returns for the years 1965 through 1969, inclusive (the relevant years). In 1971, while under criminal investigation for tax fraud, the Badaraccos filed nonfraudulent, amended returns for all relevant years. The Internal Revenue Service (IRS) (defendant) accepted these amended returns. In 1977, the IRS assessed deficiencies against the Badaraccos for each of the relevant years, determining that the Badaraccos’ tax liability included additional penalties for the initial fraud. The Badaraccos petitioned the United States Tax Court for redetermination, arguing that the IRS was barred from assessing additional taxes by a statutory three-year limitation period after the filing of their amended, nonfraudulent returns. The IRS countered that the statute of limitations did not apply because the Badaraccos’ initial returns were fraudulent. The tax court ruled in favor of the Badaraccos, and the IRS appealed. The court of appeals reversed, and the United States Supreme Court granted certiorari.

Rule of Law

Issue

Holding and Reasoning (Blackmun, J.)

Dissent (Stevens, J.)

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