Green v. Commissioner
United States Tax Court
Petitioner was a member of a partnership, known as the Raven Club, which conducted a casino-type gambling operation, including dice tables, a roulette wheel, blackjack tables, and slot machines, in Biloxi, Miss., during the taxable years involved. The partnership maintained a daily record showing its net wins or net losses, operational expenses and disbursements, and the balance of the partnership bankroll for each day.
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Petitioner was a member of a partnership, known as the Raven Club, which conducted a casino-type gambling operation, including dice tables, a roulette wheel, blackjack tables, and slot machines, in Biloxi, Miss., during the taxable years involved. The partnership maintained a daily record showing its net wins or net losses, operational expenses and disbursements, and the balance of the partnership bankroll for each day. The originals of these records, together with receipts for expenditures, were delivered monthly to an experienced accountant and former IRS agent, who maintained a journal and…
1Opinion of the Court
Bruce, Judge:
Respondent determined the following deficiencies in Federal income taxes and additions to tax against the petitioners:
Addition to tax Year Deficiency sec. 6653(b)1
1964 _ $2,078.35 $1,039.18
1965 _ 9,997.54 4,998.77
1966 _ 3,738.38 1,869.19
Two issues are presented for determination: (1) Whether petitioners had unreported income from a partnership engaged in gambling operations, and, if the first question is answered in the affirmative, (2) whether petitioners’ failure to report such income was due to fraud.
FINDINGS OF FACT
Some of the facts have been stipulated and the stipulation of…
2Cases cited18 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Wickwire v. ReineckeSupreme Court of the United States · 1927
- Mitchell v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1941
- B. B. Carter and Mrs. Tommie v. Carter v. Ellis Campbell, Jr., Director of Internal RevenueCourt of Appeals for the Fifth Circuit · 1959
13 more not listed; retrieve them via the Exa API.
3Cited by88 opinions
- Estate of Temple v. CommissionerUnited States Tax Court · 1976
- Preben Norgaard Sandra C. Norgaard v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1991
- Katz v. CommissionerUnited States Tax Court · 1988
- Schooler v. CommissionerUnited States Tax Court · 1977
- Considine v. CommissionerUnited States Tax Court · 1977
83 more not listed; retrieve them via the Exa API.