Legal Opinion

Estate of Lawrence Harrison v. Commissioner

United States Tax Court

Decided February 27, 1953No. Docket No. 33118Unpublished

The Commissioner in his determination of a deficiency against petitioner's decedent stated: Information on file in this office discloses that the following items of taxable income were not reported: (1) Commission of "kick back" received from ProsperityCo., Inc.$20,000.00(2) Salary "kick back" received from Walter E. Bell5,000.00 Held, the determination of the Commissioner is presumed to be correct and petitioner has not sustained its burden of proof to show respondent's…

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The Commissioner in his determination of a deficiency against petitioner's decedent stated: Information on file in this office discloses that the following items of taxable income were not reported: (1) Commission of "kick back" received from ProsperityCo., Inc.$20,000.00(2) Salary "kick back" received from Walter E. Bell5,000.00 Held, the determination of the Commissioner is presumed to be correct and petitioner has not sustained its burden of proof to show respondent's determination is in error. Respondent's determination is sustained for lack of evidence to overcome it. 2. The decedent…

1Opinion of the Court

Estate of Lawrence Harrison, Deceased, Martin Kingsley, Executor, v. Commissioner.

Estate of Lawrence Harrison v. Commissioner

Docket No. 33118.

United States Tax Court

1953 Tax Ct. Memo LEXIS 351; 12 T.C.M. (CCH) 196; T.C.M. (RIA) 53069;

February 27, 1953

The Commissioner in his determination of a deficiency against petitioner's decedent stated:

Information on file in this office discloses that the following items of taxable income were not reported:(1) Commission of "kick back" received from Prosperity

Co., Inc.

$20,000.00(2) Salary "kick back" received from Walter E. Bell

5,000.00

Held, the…

2Cases cited3 opinions

  1. Kellett v. CommissionerUnited States Tax Court · 1945
  2. Rockford Varnish Co. v. CommissionerUnited States Tax Court · 1947
  3. Torodor v. CommissionerUnited States Tax Court · 1952

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