Legal Opinion

Courtney v. Commissioner

United States Tax Court

Decided June 14, 1957No. Docket No. 58164PublishedCited by 153 opinions

1. The petitioner operated a country grocery store for a part of the period involved and a farm for the other part. He and his wife, both of whom were not well acquainted with accounting or bookkeeping methods, maintained records of receipts, disbursements, credit sales, and inventories. Petitioner gave certain information from his books and records to an attorney who prepared the returns.

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1. The petitioner operated a country grocery store for a part of the period involved and a farm for the other part. He and his wife, both of whom were not well acquainted with accounting or bookkeeping methods, maintained records of receipts, disbursements, credit sales, and inventories. Petitioner gave certain information from his books and records to an attorney who prepared the returns. Respondent determined petitioner's records were inadequate to determine his net income and determined petitioner's net income for the years 1949, 1950, 1951, and 1953 by the net worth method. Held, that the…

1Opinion of the Court

OPINION.

Black, Judge:

Issue 1. Net Worth Method.

The petitioner first contends that his books and records were adequate, that his tax returns were correct, and that the respondent erred in determining his income by the net worth method.

The petitioner operated a country grocery store for a part of the period involved and a farm for the other part. Neither he nor his wife, who helped him, was well acquainted with accounting or bookkeeping methods. They did, however, keep books and records for the store and the farm, in which they entered their receipts and disbursements. They kept a bank account,…

2Cases cited7 opinions

  1. Reis v. CommissionerUnited States Tax Court · 1942
  2. Stone v. CommissionerUnited States Tax Court · 1954
  3. Hartley v. CommissionerUnited States Tax Court · 1954
  4. Hurley v. CommissionerUnited States Tax Court · 1954
  5. H. A. Hurley and H. A. And Opal Hurley v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1956

2 more not listed; retrieve them via the Exa API.

3Cited by153 opinions

  1. Carlos and Jacqueline Marcello v. Commissioner of Internal Revenue, Joseph, Jr. And Anastasia Marcello v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1967
  2. Enoch v. CommissionerUnited States Tax Court · 1972
  3. Estate of Mason v. CommissionerUnited States Tax Court · 1975
  4. Stratton v. CommissionerUnited States Tax Court · 1970
  5. Vaira v. CommissionerUnited States Tax Court · 1969

148 more not listed; retrieve them via the Exa API.

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