Schultz v. Commissioner
United States Tax Court
1. Respondent determined taxable net income for the years 1946 through 1949 by the increase in net worth plus nondeductible expenditures method. With the exception of opening cash, and certain other disputed items, petitioners have accepted the correctness of the net worth computation as adjusted to give effect to certain concessions made by respondent.
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1. Respondent determined taxable net income for the years 1946 through 1949 by the increase in net worth plus nondeductible expenditures method. With the exception of opening cash, and certain other disputed items, petitioners have accepted the correctness of the net worth computation as adjusted to give effect to certain concessions made by respondent. Held, determination of net taxable income by the net worth method is approved, and findings are made as to opening cash and other disputed items. 2. During 1946, taxpayer became temporarily liable as a guarantor for an obligation of a…
1Opinion of the Court
These consolidated proceedings involve deficiencies in income tax and additions thereto in the following amounts:
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Respondent determined petitioners’ income for the taxable years 1946 through 1949 on the net worth plus personal expenditures basis. The issues for decision are: (1) What was the amount of cash on hand held by petitioners at January 1,1946; (2) did petitioners have a loan receivable as of January 1, 1946, which should have been included in their opening net worth, for that year; if so, what was the amount of that loan receivable, and did it become worthless in any of…
2Cases cited13 opinions
- Holland v. United StatesSupreme Court of the United States · 1955
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Halle v. CommissionerUnited States Tax Court · 1946
- Halle v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1949
- Rogers v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1940
8 more not listed; retrieve them via the Exa API.
3Cited by13 opinions
- Monteleone v. CommissionerUnited States Tax Court · 1960
- Bedeian v. CommissionerUnited States Tax Court · 1970
- Enrick v. CommissionerUnited States Tax Court · 1959
- Bahoric v. CommissionerUnited States Tax Court · 1963
- Bedeian v. CommissionerUnited States Tax Court · 1970
8 more not listed; retrieve them via the Exa API.