Shahadi v. Commissioner
United States Tax Court
1. Held, respondent properly reconstructed petitioners' income by the use of the net worth method, and the deficiencies determined thereby are sustained.
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1. Held, respondent properly reconstructed petitioners' income by the use of the net worth method, and the deficiencies determined thereby are sustained. Held, further, a part of each of the deficiencies for 1944 through 1950 was due to fraud with intent to evade tax; the returns for the years 1944 through 1947 were false and fraudulent with intent to evade tax; and the assessment and collection of deficiencies for the years 1944 through 1947 are not barred by the statute of limitations. 2. For the years 1945 through 1950, petitioners substantially underestimated their estimated tax. Their…
1Opinion of the Court
OPINION.
Van Fossan, Judge:
Eespondent determined, on the basis of a net worth computation, that petitioners failed to report a total of $102,277.74 during the years 1944 to 1950, inclusive. Petitioners have accepted the correctness of all items appearing in that computation with the exception of cash on hand as of December 31, 1943, and the item of “Jewelry and Furs.” They also challenge respondent’s right to resort to the net worth and expenditures method of reconstructing their income, claiming the boohs and records which they maintained during the years in issue were adequate. In addition,…
2Cases cited8 opinions
- Holland v. United StatesSupreme Court of the United States · 1955
- United States v. JohnsonSupreme Court of the United States · 1943
- Halle v. CommissionerUnited States Tax Court · 1946
- Halle v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1949
- United States v. MasseiSupreme Court of the United States · 1958
3 more not listed; retrieve them via the Exa API.
3Cited by40 opinions
- Pigman v. CommissionerUnited States Tax Court · 1958
- Sutherland v. CommissionerUnited States Tax Court · 1959
- Mazzoni v. CommissionerUnited States Tax Court · 1970
- Sunbrock v. CommissionerUnited States Tax Court · 1967
- Ehlers v. VinalCourt of Appeals for the Eighth Circuit · 1967
35 more not listed; retrieve them via the Exa API.