Legal Opinion

Sproul v. Commissioner

United States Tax Court

Decided May 15, 1995No. Docket Nos. 12590-91, 2655-93Unpublished

P was involved in the securities business during the years 1988, 1989, and 1990. During that period, P embezzled funds from clients and other investors for his personal benefit. P did not recognize these embezzled funds as income on his 1988, 1989, or 1990 Federal income tax returns.

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P was involved in the securities business during the years 1988, 1989, and 1990. During that period, P embezzled funds from clients and other investors for his personal benefit. P did not recognize these embezzled funds as income on his 1988, 1989, or 1990 Federal income tax returns. Held: P must recognize as income the funds that he embezzled from clients and other investors during the years 1988, 1989, and 1990. Held, further, P is liable for an addition to his 1988 tax for negligence under sec. 6653(a)(1), I.R.C.Held, further, P is liable for an addition to his 1989 and 1990 income taxes…

1Opinion of the Court

DENNIS E. SPROUL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Sproul v. Commissioner

Docket Nos. 12590-91, 2655-93

United States Tax Court

T.C. Memo 1995-207; 1995 Tax Ct. Memo LEXIS 209; 69 T.C.M. (CCH) 2588;

May 15, 1995, Filed

Appropriate orders will be issued denying Respondent's Motions for Sanctions, and decisions will be entered under Rule 155.

P was involved in the securities business during the years 1988, 1989, and 1990. During that period, P embezzled funds from clients and other investors for his personal benefit. P did not recognize these embezzled funds as income on his…

2Cases cited25 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Neely v. CommissionerUnited States Tax Court · 1985
  3. Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
  4. Bixby v. CommissionerUnited States Tax Court · 1972
  5. James v. United StatesSupreme Court of the United States · 1961

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