Legal Opinion

Livingston v. Commissioner

United States Tax Court

Decided April 6, 2000No. 8691-97; No. 15040-97Unpublished

H pleaded guilty to criminal tax evasion for taxable year 1990, admitting to a specified amount of unreported income as determined through R's reconstruction of H's 1990 income by the net worth method in the criminal proceeding. Subsequently, for purposes of establishing H's civil tax liability for taxable years 1989 and 1990, R determined H's unreported income by relying directly on the criminal net worth summary.

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H pleaded guilty to criminal tax evasion for taxable year 1990, admitting to a specified amount of unreported income as determined through R's reconstruction of H's 1990 income by the net worth method in the criminal proceeding. Subsequently, for purposes of establishing H's civil tax liability for taxable years 1989 and 1990, R determined H's unreported income by relying directly on the criminal net worth summary. R's 1989 net worth computation assumed that H had a zero opening net worth and was based on inconsistent inclusions of H's and W's incomes, assets, and expenditures. For taxable…

1Opinion of the Court

THERON R. LIVINGSTON, SR., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent MICHELE D. LIVINGSTON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Livingston v. Commissioner

No. 8691-97; No. 15040-97

United States Tax Court

T.C. Memo 2000-121; 2000 Tax Ct. Memo LEXIS 139; 79 T.C.M. (CCH) 1828;

April 6, 2000, Filed

Decisions will be entered under Rule 155.

H pleaded guilty to criminal tax evasion for taxable year

1990, admitting to a specified amount of unreported income as

determined through R's reconstruction of H's 1990 income by the

net worth method in the criminal proceeding.…

2Cases cited13 opinions

  1. Holland v. United StatesSupreme Court of the United States · 1955
  2. United States v. MasseiSupreme Court of the United States · 1958
  3. LTV Corp. v. CommissionerUnited States Tax Court · 1975
  4. Jerome H. Moore and Mildred v. Moore v. United States of America, Jerome H. Moore and Mildred v. Moore v. United StatesCourt of Appeals for the Fourth Circuit · 1966
  5. Brooks v. CommissionerUnited States Tax Court · 1984

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