Millikin v. Commissioner
United States Tax Court
Respondent's determination of income by increase in net worth plus nondeductible expenditures method approved with adjustments in accordance with the proof. Additions to tax under section 293(b), Internal Revenue Code of 1939 approved as to all years except 1949. Additions to tax for 1950 under sections 294(d)(1)(A) and 294(d)(2), I.R.C. 1939 approved. Held, that the statute of limitations does not bar assessment and collection of the tax liabilities.
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Respondent's determination of income by increase in net worth plus nondeductible expenditures method approved with adjustments in accordance with the proof. Additions to tax under section 293(b), Internal Revenue Code of 1939 approved as to all years except 1949. Additions to tax for 1950 under sections 294(d)(1)(A) and 294(d)(2), I.R.C. 1939 approved. Held, that the statute of limitations does not bar assessment and collection of the tax liabilities. Held, further, that respondent failed to meet his burden of proving that the petitioner Dorothy P. Millikin is liable, as transferee of assets…
1Opinion of the Court
M. S. Millikin, et al. 1 v. Commissioner.
Millikin v. Commissioner
Docket Nos. 45050-45052.
United States Tax Court
T.C. Memo 1959-210; 1959 Tax Ct. Memo LEXIS 38; 18 T.C.M. (CCH) 995; T.C.M. (RIA) 59210;
October 30, 1959
Respondent's determination of income by increase in net worth plus nondeductible expenditures method approved with adjustments in accordance with the proof.
Additions to tax under section 293(b), Internal Revenue Code of 1939 approved as to all years except 1949. Additions to tax for 1950 under sections 294(d)(1)(A) and 294(d)(2), I.R.C. 1939 approved.
Held, that the statute of…
2Cases cited33 opinions
- Holland v. United StatesSupreme Court of the United States · 1955
- Commissioner v. SternSupreme Court of the United States · 1958
- Healy v. CommissionerSupreme Court of the United States · 1953
- William J. Drieborg and Laura D. Drieborg v. Commissioner of Internal Revenue, William J. Drieborg v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1955
- Imburgia v. CommissionerUnited States Tax Court · 1954
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