Cox v. Commissioner
United States Tax Court
Petitioner applied for and received tentatives refunds of income taxes paid in 1972 and 1973 as a result of alleged net operating loss carryback deductions from 1975 and 1976, respectively.
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Petitioner applied for and received tentatives refunds of income taxes paid in 1972 and 1973 as a result of alleged net operating loss carryback deductions from 1975 and 1976, respectively. Respondent later determined that after certain adjustments petitioner's net operating loss for 1975 was much less than claimed by petitioner in her refund application and that petitioner did not have a net operating loss for 1976. Deficiency determinations for carryback years 1972 and 1973 resulted. Held, the sources and applications of funds method is an acceptable method of income reconstruction, was…
1Opinion of the Court
ALMEDA COX, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent.
Cox v. Commissioner
Docket No. 10861-78.
United States Tax Court
T.C. Memo 1980-244; 1980 Tax Ct. Memo LEXIS 343; 40 T.C.M. (CCH) 619; T.C.M. (RIA) 80244;
July 9, 1980, Filed
Petitioner applied for and received tentatives refunds of income taxes paid in 1972 and 1973 as a result of alleged net operating loss carryback deductions from 1975 and 1976, respectively. Respondent later determined that after certain adjustments petitioner's net operating loss for 1975 was much less than claimed by petitioner in her refund application…
2Cases cited37 opinions
- Holland v. United StatesSupreme Court of the United States · 1955
- United States v. JohnsonSupreme Court of the United States · 1943
- United States v. MasseiSupreme Court of the United States · 1958
- Schroeder v. CommissionerUnited States Tax Court · 1963
- Sharon v. CommissionerUnited States Tax Court · 1976
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