Ernest BADARACCO, Sr. and Rose Badaracco, Ernest Badaracco, Jr. and Barbara Badaracco,
v.
COMMISSIONER OF INTERNAL REVENUE, Appellant in No. 81-3033.
DELEET MERCHANDISING CORP.
v.
UNITED STATES of America, Appellant in No. 82-5171.
United States Court of Appeals, Third Circuit.https://leagle.com/images/logo.png
Argued September 16, 1982.
Decided November 29, 1982.
Attorney(s) appearing for the Case
Glenn L. Archer, Jr., Asst. Atty. Gen., Michael L. Paup, Gary R. Allen, John A. Dudeck, Jr. (argued), Tax Division, Dept. of Justice, Washington, D.C., for appellant in No. 81-3033.
Glenn L. Archer, Jr., Asst. Atty. Gen., Michael L. Paup, Gary R. Allen, John A. Dudeck, Jr. (argued), Tax Division, Dept. of Justice, Washington, D.C., for appellant in No. 82-5171.
Starr, Weinberg & Fradkin, Roseland, N.J., for appellees in No. 81-3033; John J. O'Toole (argued), Roseland, N.J., of counsel.
Fredericks & Messinger, Hackensack, N.J., and Goldschmidt, Fredericks & Oshatz, New York City, for appellee in No. 82-5171; Barry I. Fredericks (argued), Richard H. Waxman, S. Timothy Ball, New York City, of counsel.
Before ADAMS, HUNTER and BECKER, Circuit Judges.
United States Court of Appeals, Third Circuit.
OPINION OF THE COURT
ADAMS, Circuit Judge.
These two appeals1 concern the effect of filing nonfraudulent, amended income tax returns, subsequent to the filing of fraudulent original returns, on the statute of limitations provisions of 26 U.S.C. § 6501.2
I.
The facts in each proceeding are undisputed.3 In the first case, Ernest Badaracco, Sr. and...
Let's get started
Welcome to the leading source of independent legal reporting Sign on now to see your case. Or view more than 10 million decisions and orders.
Updated daily.
Uncompromising quality.
Complete, Accurate, Current.
Listed below are the cases that are cited in this Featured Case. Click the citation to see the full
text of the cited case. Citations are also linked in the body of the Featured Case.
Cited Cases
No Cases Found
Listed below are those cases in which this Featured Case is cited. Click on the case name to see the
full text of the citing case.