Gleis v. Commissioner
United States Tax Court
1. Respondent's computation of income by means of the so-called increase in net worth method approved subject to certain adjustments. 2. Held, some part of the deficiency for the year 1947 was due to fraud with intent to evade tax. 3. Held, the statute of limitations bars assessment and collection of the deficiency for certain of the taxable years.
1Opinion of the Court
OPINION.
Van Fossan, Judge:
At the outset petitioner protests respondent’s resort to the increase in net worth and expenditures method of computing income for the years involved. It is petitioner’s contention that the books and records maintained for him by Ann were and are sufficient for the purpose of determining income; that had the necessary effort been made, an accurate computation of income could have been made therefrom; and that respondent’s failure so to do was arbitrary and capricious. Precisely, petitioner repeatedly insists that his books of account adequately reflect his income for…
2Cases cited5 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Helvering v. MitchellSupreme Court of the United States · 1938
- Bowen v. CommissionerUnited States Tax Court · 1949
- Leonard Refineries, Inc. v. CommissionerUnited States Tax Court · 1948
- Bartlett v. CommissionerUnited States Tax Court · 1954
3Cited by66 opinions
- Estate of Beck v. Comm'rUnited States Tax Court · 1971
- Fox v. CommissionerUnited States Tax Court · 1974
- Nell La Compte Reaves, as of the Will of Jesse Ullman Reaves, Deceased v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1961
- Shahadi v. CommissionerUnited States Tax Court · 1958
- Jones v. CommissionerUnited States Tax Court · 1957
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