Romanelli v. Commissioner
United States Tax Court
Petitioner Hugo Romanelli owned and operated a tavern from 1961 through 1964, the taxable years in question. On Oct. 29, 1964, based upon the affidavit of a special agent who had investigated petitioner's tavern in an undercover capacity, a search warrant was issued authorizing the search of such tavern.
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Petitioner Hugo Romanelli owned and operated a tavern from 1961 through 1964, the taxable years in question. On Oct. 29, 1964, based upon the affidavit of a special agent who had investigated petitioner's tavern in an undercover capacity, a search warrant was issued authorizing the search of such tavern. The search warrant was founded upon the belief that petitioner had engaged in wagering activities in violation of secs. 4412 and 4905, I.R.C. 1954. On the same day the warrant was issued four special agents of the Internal Revenue Service entered petitioner's premises, served the search…
1Opinion of the Court
OPINION
The issues in this case are whether petitioner had unreported income from wagering activities during the taxable years in question and, if so, whether his failure to report such income justified the imposition of additions to tax for fraud under section 6653(b). The disposition of these issues turns in large measure upon several evidentiary questions first presented to the Court prior to trial as a motion for the suppression of evidence. After hearing argument on the motion the Court ordered the parties to proceed with the trial and advised petitioner that he would be permitted to…
2Cases cited53 opinions
- Miranda v. ArizonaSupreme Court of the United States · 1966
- Katz v. United StatesSupreme Court of the United States · 1967
- Mapp v. OhioSupreme Court of the United States · 1961
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- Simmons v. United StatesSupreme Court of the United States · 1968
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3Cited by25 opinions
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