Estate of Emanuel Trompeter, Deceased, Robin Carol Trompeter Gonzalez and Janet Ilene Trompeter Polacheck, Co-Executors - Page 19

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          The phrase “tax required to be shown on a return” is described in           
          the committee report as “all taxes for which returns are                    
          required”.  S. Rept. 83-1622 at 591.  That phrase is used to set            
          off the section 6653(b), I.R.C. 1954 rules from the rules                   
          applying to “any tax imposed by this title which is payable by              
          stamp, coupons, tickets, books, or other devices”, which are                
          collectively referred to in the committee report as “any stamp              
          tax” S. Rept. 83-1622, at 591, and which appear in the statute at           
          section 6653(e), I.R.C. 1954.                                               
               The classification interpretation is clear from the                    
          legislative events of 1954 and the committee reports.  One                  
          searches in vain for any legislative events of 1954 or                      
          explanations in the course of the enactment of the 1954 Code that           
          suggests that the phrase in dispute should be given a temporal              
          interpretation, whether as to fraud or in general.                          

               SWIFT, PARR, WHALEN, LARO, VASQUEZ, GALE, and MARVEL, JJ.,             
          agree with this concurring opinion.                                         

















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