Arthur L. Lawrence and Alma P. Lawrence v. Commissioner of Internal Revenue
Cases that cite this one
41 later published cases cite this decision. The 25 that cite it most often are listed here.
- Raju J. Mukhi (United States Tax Court 2024)
- Mertes v. Internal Revenue Service (United States District Court for the Eastern District of California 2021)
- Tigers Eye Trading, LLC, Sentinel Advisors, LLC, Tax Matters Partner v. Commissioner (United States Tax Court 2012)
- Tigers Eye Trading, LLC v. Comm'r (United States Tax Court 2012)
- Benson v. Commissioner (9th Cir. 2009)
- Trout v. Comm'r (United States Tax Court 2008)
- David Bruce Billings v. Commissioner (United States Tax Court 2006)
- Central Pa. Sav. Ass'n v. Commissioner (United States Tax Court 1995)
- Peat Oil & Gas Assocs. v. Commissioner (United States Tax Court 1993)
- Tobler v. Derwinski (United States Court of Veteran Appeals 1991)
- Bokum v. Commissioner (United States Tax Court 1990)
- Blake v. Comm'r (United States Tax Court 1976)
- Roy v. Commissioner (United States Tax Court 1970)
- Commissioner of Internal Revenue v. James B. Kelley and Lena S. Kelley, and John Waltman and Doris Waltman (5th Cir. 1961)
- May Broadcasting Co. v. Commissioner (United States Tax Court 1960)
- De Woskin v. Commissioner (United States Tax Court 1960)
- Kelley v. Commissioner (United States Tax Court 1959)
- Automobile Club of New York, Inc. v. Commissioner (United States Tax Court 1959)
- Jack Goodwill-Oikerhe (United States Tax Court 2026)
- Valley Park Ranch, LLC, Reed Oppenheimer, Tax Matters Partner (United States Tax Court 2024)
- Mohamed K. Abdo & Fardowsa J. Farah (United States Tax Court 2024)
- Raju J. Mukhi (United States Tax Court 2024)
- David W. Tice (United States Tax Court 2023)
- Tiffany Lashun Sanders (United States Tax Court 2023)
- 901 South Broadway Limited Partnership, Standard Development, LLC, Tax Matters Partner (United States Tax Court 2021)
This list shows which later cases cite this one. It does not say how they treated it, and no review of that has been done. Not a substitute for Shepard’s or KeyCite — verify before relying.
Opinion
When a taxpayer has made a full disclosure of his “position” with respect to his gross income on his income tax return (a disclosure that would arrest the attention of the Internal Revenue Service upon its examination of the return), but has not “included” the amount involved as taxable, is the Collector of Internal Revenue subject to the ordinary three year limitation of § 275(a) 1 or to the special five year statute, § 275(c), of the Internal Revenue Code of 1939 ? 2
No fraud was suggested. 3
The Tax Court, rejecting Slaff v. Commissioner, 9 Cir., 220 F.2d 65, held the *563 five year statute applicable and that the collector’s notice of deficiency mailed four years, eleven months and ten days after the filing of the return in 1949 was timely.
After this case was argued, the Supreme Court granted certiorari in a parallel case, Colony, Inc., v. Commissioner of Internal Revenue, 355 U.S. 811, 78 S.Ct. 51, 2 L.Ed.2d 29. See same case, in the Sixth Circuit, 244 F.2d 75.
The Supreme Court has now reversed Colony, 78 S.Ct. 1033, decided June 9, 1958. On the authority of Colony, the decision of the Tax Court is reversed.
Case-law data current through December 31, 2025. Source: CourtListener bulk data.