James R. Lockwood and Joyce M. Lockwood v. Commissioner of Internal Revenue

Ninth Circuit

James R. Lockwood and Joyce M. Lockwood v. Commissioner of Internal Revenue

435 F.2d 1308, 27 A.F.T.R.2d (RIA) 71

CourtCourt of Appeals for the Ninth Circuit

DecidedJanuary 15, 1971

Docket24384

StatusPublished

Cited by1 cases

This text of 435 F.2d 1308 (James R. Lockwood and Joyce M. Lockwood v. Commissioner of Internal Revenue) is published on Counsel Stack Legal Research, covering Court of Appeals for the Ninth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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James R. Lockwood and Joyce M. Lockwood v. Commissioner of Internal Revenue, 435 F.2d 1308, 27 A.F.T.R.2d (RIA) 71 (9th Cir. 1971).

Pincite

Opinion

PER CURIAM:

The decision of the tax court is affirmed except as to the assessment of a negligence penalty on the wife’s separate return.

The deficiencies found in reporting were simply the resolution of factual questions.

The case on the deficiencies could have been resolved the other way, but we cannot find the tax court was clearly erroneous.

As to Mrs. Lockwood, the record seems clear that she was wholly inert in the business transactions and the tax reporting. We cannot sustain the small negligence penalty as to her.

Remanded for proceedings consistent herewith.

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