Conforte v. Commissioner
United States Tax Court
Petitioners owned and operated a legal house of prostitution, Mustang Ranch Brothel, Nev. The only contemporaneously prepared document evidencing the income of the prostitution during the years in issue was a sheet showing earnings of each prostitute during a 24-hour period. Petitioners also owned the Starlight Ranch Brothel.
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Petitioners owned and operated a legal house of prostitution, Mustang Ranch Brothel, Nev. The only contemporaneously prepared document evidencing the income of the prostitution during the years in issue was a sheet showing earnings of each prostitute during a 24-hour period. Petitioners also owned the Starlight Ranch Brothel. For the calendar years 1973 through 1976, petitioners filed a "Sullivan" Form 1040. Held: 1. Gross income from the Mustang and Starlight brothels determined; 2. Business expenses determined; 3. Amount of deductible legal fees determined; 4. Applicability of sec. 170…
1Opinion of the Court
Sterrett, Judge:
By statutory notice dated April 14, 1978, respondent determined a deficiency in Mr. Joseph Conforte’s income taxes and additions to tax as follows:
Sec. 6653(b) Year Deficiency addition to tax
1973.$1,142,054.00 $598,943.00
1974.1,189,391.00 622,701.50
1975. 1,228,480.20 642,248.60
1976.1,207,831.00 631,918.00
On the same day, a similar statutory notice of deficiency was sent to Mrs. Conforte. The deficiency and additions to tax pertaining to Mrs. Conforte were slightly lower than those stated above for the reason that self-employment tax was attributed only to Mr. Conforte.
These…
2Cases cited60 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Spies v. United StatesSupreme Court of the United States · 1943
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Marchetti v. United StatesSupreme Court of the United States · 1968
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3Cited by70 opinions
- Jarvis v. CommissionerUnited States Tax Court · 1982
- Sally Conforte v. Commissioner of Internal Revenue, Joseph Conforte v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1982
- Kluger v. CommissionerUnited States Tax Court · 1984
- Borchers v. CommissionerUnited States Tax Court · 1990
- Thompson v. CommissionerUnited States Tax Court · 1982
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