Costa v. Commissioner
United States Tax Court
P's son was arrested in 1984 while driving H's (P's husband) car containing narcotics and cash. In 1986, H was convicted on narcotics related charges. H subsequently fled prosecution and was a fugitive from justice at the time of this proceeding. In 1984 P and H were married but did not have a relationship of a nature which would allow us to attribute knowledge of H's activities between them. R reconstructed H's 1984 income using the cash expenditures method.
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P's son was arrested in 1984 while driving H's (P's husband) car containing narcotics and cash. In 1986, H was convicted on narcotics related charges. H subsequently fled prosecution and was a fugitive from justice at the time of this proceeding. In 1984 P and H were married but did not have a relationship of a nature which would allow us to attribute knowledge of H's activities between them. R reconstructed H's 1984 income using the cash expenditures method. Thereafter, R issued a statutory notice to P imputing one-half of such reconstructed income to her on the basis of California community…
1Opinion of the Court
SANDRA M. COSTA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Costa v. Commissioner
Docket No. 6652-88
United States Tax Court
T.C. Memo 1990-572; 1990 Tax Ct. Memo LEXIS 644; 60 T.C.M. (CCH) 1178; T.C.M. (RIA) 90572;
October 31, 1990, Filed
Decision will be entered for the petitioner.
P's son was arrested in 1984 while driving H's (P's husband) car containing narcotics and cash. In 1986, H was convicted on narcotics related charges. H subsequently fled prosecution and was a fugitive from justice at the time of this proceeding. In 1984 P and H were married but did not have a…
2Cases cited66 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Holland v. United StatesSupreme Court of the United States · 1955
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Helvering v. TaylorSupreme Court of the United States · 1935
- United States v. JohnsonSupreme Court of the United States · 1943
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