Legal Opinion

Crabtree v. Commissioner

United States Tax Court

Decided August 27, 1984No. Docket No. 7985-78Unpublished

During 1973, 1974, and 1975, P engaged in transactions involving investments in silver and made large bank deposits.P filed returns for 1973 and 1974 but did not file a return for 1975. The Commissioner, using the bank deposits method, determined that P had unreported income during each of the years in issue.

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During 1973, 1974, and 1975, P engaged in transactions involving investments in silver and made large bank deposits.P filed returns for 1973 and 1974 but did not file a return for 1975. The Commissioner, using the bank deposits method, determined that P had unreported income during each of the years in issue. Held: (1) P has failed to prove that he did not have unreported income during the years in issue as determined by the Commissioner in his revised bank deposits analysis. (2) P is liable for the addition to tax for negligence under sec. 6653(a), I.R.C. 1954, for 1973, 1974, and 1975. (3)…

1Opinion of the Court

GEORGE B. and BERNELL L. CRABTREE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Crabtree v. Commissioner

Docket No. 7985-78.

United States Tax Court

T.C. Memo 1984-450; 1984 Tax Ct. Memo LEXIS 224; 48 T.C.M. (CCH) 948; T.C.M. (RIA) 84450;

August 27, 1984.

During 1973, 1974, and 1975, P engaged in transactions involving investments in silver and made large bank deposits.P filed returns for 1973 and 1974 but did not file a return for 1975. The Commissioner, using the bank deposits method, determined that P had unreported income during each of the years in issue.

Held:(1) P has failed to…

2Cases cited27 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Holland v. United StatesSupreme Court of the United States · 1955
  3. Bixby v. CommissionerUnited States Tax Court · 1972
  4. Grosshandler v. CommissionerUnited States Tax Court · 1980
  5. Halle v. CommissionerUnited States Tax Court · 1946

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