George Schwarzkopf v. Commissioner of Internal Revenue

STALEY, Circuit Judge.

A challenge to the Commissioner’s use of the net worth method of determining income is presented by this petition seeking review of a decision of the Tax Court of the United States.

Petitioner George Schwarzkopf, an oculist and eye surgeon, was a resident of Atlantic City, New Jersey, during 1947 through 1951, the taxable years under review. His residence contained not only his living quarters but also his office, operating room, and hospital rooms. Taxpayer kept his own receipts book from which he reported his yearly income. He admitted that many of the sums entered on…