Llorente v. Commissioner
United States Tax Court
Based upon information furnished to an undercover agent by an informant and the agent's personal knowledge, respondent determined that petitioner purchased cocaine during 1974. Held: Sufficient evidence introduced to render statutory notice not arbitrary and excessive. Jackson v. Commissioner, 73 T.C. 394 (1979), and Weimerskirch v. Commissioner, 596 F.2d 358 (9th Cir. 1979), revg. 67 T.C. 672 (1977), distinguished. Taxable income determined under the expenditures method.
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Based upon information furnished to an undercover agent by an informant and the agent's personal knowledge, respondent determined that petitioner purchased cocaine during 1974. Held: Sufficient evidence introduced to render statutory notice not arbitrary and excessive. Jackson v. Commissioner, 73 T.C. 394 (1979), and Weimerskirch v. Commissioner, 596 F.2d 358 (9th Cir. 1979), revg. 67 T.C. 672 (1977), distinguished. Taxable income determined under the expenditures method. Held, further, dependency exemption deduction determined.
1Opinion of the Court
Sterrett, Judge:
By letter dated September 17, 1976, respondent determined a deficiency in petitioner’s income taxes for the taxable year ended December 31, 1974, in the amount of $29,403.76. Respondent has also determined additions to tax pursuant to sections 6651(a), 6653(a), and 6654(a), I.R.C. 1954, in the amounts of $7,350.94, $1,470.19, and $940.93, respectively. After concessions, the primary issue remaining is whether petitioner had unreported income evidenced by his mortgage payments and purchase of cocaine in 1974, as determined by respondent utilizing the expenditures method to…
Also in this document: Concurrence.
2Cases cited20 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- United States v. JanisSupreme Court of the United States · 1976
- Helvering v. TaylorSupreme Court of the United States · 1935
- Wichita Term. El. Co. v. Commissioner of Int. R.Court of Appeals for the Tenth Circuit · 1947
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3Cited by137 opinions
- Tokarski v. CommissionerUnited States Tax Court · 1986
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- Southern Pacific Transp. Co. v. CommissionerUnited States Tax Court · 1980
- Estate of Andrews v. CommissionerUnited States Tax Court · 1982
- Foster v. Comm'rUnited States Tax Court · 1983
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