Pigman v. Commissioner
United States Tax Court
Petitioner, during the years 1947 to 1952, inclusive, was engaged as a private investigator and advisor to a wealthy widow. For her services she received approximately $ 250,000, which sums were compensatory in nature. Petitioner did not include these sums on her income tax returns for the above-stated years. Held, that petitioner understated taxable income on her returns for each of the years 1947 to 1952, inclusive. Amounts of the understatements determined.
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Petitioner, during the years 1947 to 1952, inclusive, was engaged as a private investigator and advisor to a wealthy widow. For her services she received approximately $ 250,000, which sums were compensatory in nature. Petitioner did not include these sums on her income tax returns for the above-stated years. Held, that petitioner understated taxable income on her returns for each of the years 1947 to 1952, inclusive. Amounts of the understatements determined. Held, further, that a part of the deficiency for each of the years 1947 to 1952, inclusive, was due to fraud with intent to evade…
1Opinion of the Court
Fisher, Judge:
This proceeding involves deficiencies in income tax and additions to tax determined against petitioner as follows:
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The issues presented for our consideration are: (a) Whether, and to what extent, petitioner omitted taxable income from her return for each of the years 1947, 1948, 1949, 1950, 1951, and 1952; (b) whether any part of the deficiency for each of the years in question is due to fraud with intent to evade tax; (c) whether the deficiencies for the years 1947 through 1951 are barred by the statute of limitations; and (d) whether the petitioner is liable for…
2Cases cited24 opinions
- United States v. CalderonSupreme Court of the United States · 1954
- Lewis Thurston Anderson and Clyde Velma Anderson, Lewis Thurston Anderson v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1957
- 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
- Rogers v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1940
19 more not listed; retrieve them via the Exa API.
3Cited by103 opinions
- Petzoldt v. CommissionerUnited States Tax Court · 1989
- Miller v. CommissionerUnited States Tax Court · 1969
- Neaderland v. CommissionerUnited States Tax Court · 1969
- Conforte v. CommissionerUnited States Tax Court · 1980
- Heman v. CommissionerUnited States Tax Court · 1959
98 more not listed; retrieve them via the Exa API.