Cox v. Commissioner
United States Tax Court
1. The petitioner has, since 1951, been engaged in farming. He failed to file income tax returns for the taxable years 1951 through 1963. In the absence of adequate records, the respondent computed the petitioner's taxable income on the net worth plus nondeductible expenditures method.
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1. The petitioner has, since 1951, been engaged in farming. He failed to file income tax returns for the taxable years 1951 through 1963. In the absence of adequate records, the respondent computed the petitioner's taxable income on the net worth plus nondeductible expenditures method. The petitioner had no net worth at Jan. 1, 1951, and it was possible to compute his net worth as of Dec. 31, 1963. However, the petitioner's net worth as of the end of any of the intervening years could not be determined. Accordingly, the respondent computed the petitioner's increase in net worth over the…
1Opinion of the Court
Adell D. Cox and Mary T. Cox, Petitioners v. Commissioner of Internal Revenue, Respondent
Cox v. Commissioner
Docket No. 5761-66
United States Tax Court
54 T.C. 1735; 1970 U.S. Tax Ct. LEXIS 63;
September 24, 1970, Filed
Decision will be entered for the respondent.
1. The petitioner has, since 1951, been engaged in farming. He failed to file income tax returns for the taxable years 1951 through 1963. In the absence of adequate records, the respondent computed the petitioner's taxable income on the net worth plus nondeductible expenditures method. The petitioner had no net worth at Jan. 1, 1951, and…
2Cases cited7 opinions
- Rodney v. Comm'rUnited States Tax Court · 1969
- Heman v. CommissionerUnited States Tax Court · 1959
- Hurley v. CommissionerUnited States Tax Court · 1954
- Bartlett v. CommissionerUnited States Tax Court · 1954
- H. A. Hurley and H. A. And Opal Hurley v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1956
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