Jedinak v. Commissioner
United States Tax Court
P operated a numbers business from 1968 through 1971 but reported no income from such business on his Federal income tax returns for such years.
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P operated a numbers business from 1968 through 1971 but reported no income from such business on his Federal income tax returns for such years. Held: (1) P grossly understated his income each year from 1968 through 1971; (2) some part of the underpayment for each of the years at issue was due to P's fraud with intent to evade tax within the meaning of sec. 6653(b), I.R.C. 1954; (3) the Commissioner has failed to prove that any part of the underpayment was due to fraud on the part of P's wife; (4) P's wife has not proved that she is entitled to the relief from liability for the deficiencies…
1Opinion of the Court
EDWARD J. JEDINAK and LUCILLE M. JEDINAK, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Jedinak v. Commissioner
Docket No. 2754-75.
United States Tax Court
T.C. Memo 1978-227; 1978 Tax Ct. Memo LEXIS 291; 37 T.C.M. (CCH) 965; T.C.M. (RIA) 78227;
June 19, 1978, Filed
P operated a numbers business from 1968 through 1971 but reported no income from such business on his Federal income tax returns for such years. Held: (1) P grossly understated his income each year from 1968 through 1971; (2) some part of the underpayment for each of the years at issue was due to P's fraud with intent to…
2Cases cited39 opinions
- Holland v. United StatesSupreme Court of the United States · 1955
- Spies v. United StatesSupreme Court of the United States · 1943
- Stone v. CommissionerUnited States Tax Court · 1971
- Beaver v. CommissionerUnited States Tax Court · 1970
- Otsuki v. CommissionerUnited States Tax Court · 1969
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