Alvarez v. Commissioner
United States Tax Court
H was arrested in 1985 and charged with conspiracy to distribute cocaine. When H was arrested, Ps possessed $ 551,000 in cash and $ 92,772 in cash equivalents. R used the net worth method to determine deficiencies in, and additions to, Ps' 1982 through 1984 Federal income taxes. R used the bank deposits method to determine deficiencies in, and additions to, H's 1985 through 1987 and 1989 Federal income taxes.
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H was arrested in 1985 and charged with conspiracy to distribute cocaine. When H was arrested, Ps possessed $ 551,000 in cash and $ 92,772 in cash equivalents. R used the net worth method to determine deficiencies in, and additions to, Ps' 1982 through 1984 Federal income taxes. R used the bank deposits method to determine deficiencies in, and additions to, H's 1985 through 1987 and 1989 Federal income taxes. Ps allege that R's determinations were arbitrary and capricious, and that the source of the income was a gift. W seeks innocent spouse relief under sec. 6013(e), I.R.C., for her 1982…
1Opinion of the Court
JOSE A. ALVAREZ AND WANDA ALVAREZ, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent; JOSE A. ALVAREZ, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Alvarez v. Commissioner
Docket Nos. 2849-91, 22719-93.
United States Tax Court
T.C. Memo 1995-414; 1995 Tax Ct. Memo LEXIS 416; 70 T.C.M. (CCH) 518;
August 24, 1995, Filed
Decisions will be entered under Rule 155.
H was arrested in 1985 and charged with conspiracy to distribute cocaine. When H was arrested, Ps possessed $ 551,000 in cash and $ 92,772 in cash equivalents. R used the net worth method to determine deficiencies in,…
2Cases cited42 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Holland v. United StatesSupreme Court of the United States · 1955
- Spies v. United StatesSupreme Court of the United States · 1943
- United States v. JanisSupreme Court of the United States · 1976
- United States v. BoyleSupreme Court of the United States · 1985
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