Topic: a deficiency assessment may be sustained upon any legal gro… · Go Syfert
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Topic #7407

6 canonical passages across 5 cases, quoted by 48 opinions in total. These passages cluster together because the same opinions keep quoting them side by side — they state parts of one doctrine. The anchor passage is from F.B. Blansett and Ethel Blansett v. United States.

#Case FlagCanonical passage Citers
1 F.B. Blansett and Ethel Blansett v. United States Anchor
ca8 · 1960
green “a deficiency assessment may be sustained upon any legal ground supporting it, - 16 - even though the commissioner did not rely thereon when the assessment was made.” 8
2 Burma Hills Development Co. v. Marr
ala · 1969
green “for residential purposes only.” 8
3 Burma Hills Development Co. v. Marr
ala · 1969
green “taken for and devoted to a public purpose.” 8
4 Mileham v. Comm'r
tax · 2017
green “under all the circumstances, such reliance was reasonable and the taxpayer acted in good faith.” 8
5 John E. Rogers & Frances L. Rogers v. Commissioner
tax · 2019
green “the section 6662(a) and (h) penalties are distinct (despite the title of section 6662 referring to a (singular) penalty), and the initial determination under each subsection must be separately approved for purposes of section 6751(b)(1).” 8
6 Wells Fargo & Company v. United States
ca8 · 2020
green “the reasonable cause and good faith exception may provide relief from the penalty of negligence even if a return position does not satisfy the reasonable basis standard.” 8

A red or yellow flag on a member means the underlying case has negative treatment — for those, check the case page before relying on the passage.

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