Estate of Mason v. Commissioner
United States Tax Court
1. Deposits in petitioners' savings and checking accounts far exceeded their reported income. They kept no books or records of their income, and when an internal revenue agent investigated their returns, they failed to give any plausible explanation for the large amount of deposits. An explanation, offered for the first time at trial, indicated that some of the deposits were not income, and thereupon the Commissioner so conceded.
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1. Deposits in petitioners' savings and checking accounts far exceeded their reported income. They kept no books or records of their income, and when an internal revenue agent investigated their returns, they failed to give any plausible explanation for the large amount of deposits. An explanation, offered for the first time at trial, indicated that some of the deposits were not income, and thereupon the Commissioner so conceded. Held, the Commissioner's determination to reconstruct their income by the bank deposit method was not arbitrary or unreasonable; held, further, the explanation…
1Opinion of the Court
Simpson, Judge:
The Commissioner determined the following deficiencies in and additions to the petitioners’ Federal income tax:
Additions to tax
Year Deficiency sec. 6653(a)1
1966 _ $63,280.97 $3,164.05
1967 _ 390,533.62 19,526.68
The issues to be decided are: (1) Whether the burden of proving the petitioners’ gross income for 1966 and 1967 is on the Commissioner; (2) what income the petitioners actually received in 1966 and 1967; and (3) whether any part of the underpayment of the petitioners’ tax for 1966 and 1967 was due to negligence or intentional disregard of rules and regulations.
FINDINGS OF…
2Cases cited39 opinions
- Helvering v. TaylorSupreme Court of the United States · 1935
- Bixby v. CommissionerUnited States Tax Court · 1972
- Roberts v. CommissionerUnited States Tax Court · 1974
- Halle v. CommissionerUnited States Tax Court · 1946
- Halle v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1949
34 more not listed; retrieve them via the Exa API.
3Cited by249 opinions
- Tokarski v. CommissionerUnited States Tax Court · 1986
- Parks v. CommissionerUnited States Tax Court · 1990
- Estate of Mary Mason, Deceased, Herbert L. Harris, Administrator, and Robert Mason v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1977
- Meier v. CommissionerUnited States Tax Court · 1988
- Clayton v. CommissionerUnited States Tax Court · 1994
244 more not listed; retrieve them via the Exa API.