Durovic v. Commissioner
United States Tax Court
1. Held, the good-faith filing of a Form 1065 partnership return reflecting petitioner's only source of income was not sufficient to start the running of the statute of limitations where petitioner had failed to file an individual return, as required by sec. 6012(a). 2. Held, petitioner incorrectly used the "official" rate of exchange (as opposed to the "commercial" rate of exchange) in converting the cost of Argentinian expenditures, incurred prior to petitioner's…
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1. Held, the good-faith filing of a Form 1065 partnership return reflecting petitioner's only source of income was not sufficient to start the running of the statute of limitations where petitioner had failed to file an individual return, as required by sec. 6012(a). 2. Held, petitioner incorrectly used the "official" rate of exchange (as opposed to the "commercial" rate of exchange) in converting the cost of Argentinian expenditures, incurred prior to petitioner's emigration to this country, into dollars. 3. Held, respondent's determination not arbitrary or unreasonable where respondent's…
1Opinion of the Court
OPINION
In 1942, petitioner Marko and his brother, Stevan, emigrated from Europe to Argentina. Stevan was a doctor of medicine and a research scientist. His research had been in the field of cancer. Upon his arrival in South America Stevan contacted various persons in the Argentinian scientific community with a view toward resuming his research work. With financial backing from a relative of Marko’s wife, Stevan was able to resume his search for a stimulant active against cancer.
While searching- for this stimulant, Stevan, in 1944, unexpectedly discovered a substance (Kositerin) which showed…
2Cases cited66 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Helvering v. TaylorSupreme Court of the United States · 1935
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
- Mitchell v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1941
61 more not listed; retrieve them via the Exa API.
3Cited by112 opinions
- Petzoldt v. CommissionerUnited States Tax Court · 1989
- Cupp v. CommissionerUnited States Tax Court · 1975
- Roberts v. CommissionerUnited States Tax Court · 1974
- Estate of Mason v. CommissionerUnited States Tax Court · 1975
- McGee v. CommissionerUnited States Tax Court · 1973
107 more not listed; retrieve them via the Exa API.