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  • William Moore Smith v. Commissioner of Internal Revenue, 849 F.2d 606, 4th Cir. (1988)

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    The United States Court of Appeals for the Fourth Circuit affirmed the decision of the Tax Court, which determined that William M. Smith was not entitled to an income exclusion under 26 U.S.C. Sec. 105 and had negligently failed to report $1,001 in dividend income for the 1982 tax year. The Court of Appeals found the Tax Court's determinations to be proper based on its reasoning. As the facts and legal issues were fully set out in the case materials, the Court of Appeals dispensed with oral arguments.

    Original Description:

    Filed: 1988-06-06 Precedential Status: Non-Precedential Citations: 849 F.2d 606 Docket: 88-1517

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    The United States Court of Appeals for the Fourth Circuit affirmed the decision of the Tax Court, which determined that William M. Smith was not entitled to an income exclusion under 26 U.S.C. Sec. 105 and had negligently failed to report $1,001 in dividend income for the 1982 tax year. The Court of Appeals found the Tax Court's determinations to be proper based on its reasoning. As the facts and legal issues were fully set out in the case materials, the Court of Appeals dispensed with oral arguments.

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    6 views2 pages

    William Moore Smith v. Commissioner of Internal Revenue, 849 F.2d 606, 4th Cir. (1988)

    Uploaded by

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    The United States Court of Appeals for the Fourth Circuit affirmed the decision of the Tax Court, which determined that William M. Smith was not entitled to an income exclusion under 26 U.S.C. Sec. 105 and had negligently failed to report $1,001 in dividend income for the 1982 tax year. The Court of Appeals found the Tax Court's determinations to be proper based on its reasoning. As the facts and legal issues were fully set out in the case materials, the Court of Appeals dispensed with oral arguments.

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    of 2

    849 F.

    2d 606
    Unpublished Disposition

    NOTICE: Fourth Circuit I.O.P. 36.6 states that citation of


    unpublished dispositions is disfavored except for establishing
    res judicata, estoppel, or the law of the case and requires
    service of copies of cited unpublished dispositions of the Fourth
    Circuit.
    William Moore SMITH, Petitioner-Appellant,
    v.
    COMMISSIONER OF INTERNAL REVENUE, RespondentAppellee.
    No. 88-1517.

    United States Court of Appeals, Fourth Circuit.


    Submitted: April 28, 1988.
    Decided: June 6, 1988.

    William Moore Smith, appellant pro se.


    Gary R. Allen (U.S. Department of Justice), for appellee.
    Before JAMES DICKSON PHILLIPS, MURNAGHAN and CHAPMAN,
    Circuit Judges.
    PER CURIAM:

    A review of the record, the opinion of the tax court, and the materials
    submitted by the parties on appeal reveals that the tax court's determinations
    that William M. Smith was not entitled to an income exclusion pursuant to 26
    U.S.C. Sec. 105 and negligently failed to report $1,001 of dividend income for
    the tax year 1982 were proper. We accordingly affirm the decision of the Tax
    Court based on its reasoning. Smith v. Commissioner, No. 2172-86 (T.C.1987).

    Because the facts and legal contentions are adequately developed in the
    materials before the Court and oral argument would not aid in the decisional
    process, we dispense with argument in this case.

    AFFIRMED.

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