Legal Opinion
David H. Schultz and Bessie Schultz v. Commissioner of Internal Revenue
Court of Appeals for the Fifth Circuit
Decided May 30, 1960No. 17914_1PublishedCited by 17 opinions
1Opinion of the Court
JOHN R. BROWN, Circuit Judge.
This case presents problems arising under the net worth plus nondeductible expenses method of reconstructing income. On the basis of it, the Commissioner asserted substantial deficiencies against Taxpayer (and his wife), together with penalties for fraud, 26 U.S. C.A. § 293(b), and under 26 U.S.C.A. § 294(d) (1) (B) & § 294(d) (2) [1939 I.R.C.] for the years 1946, 1947, 1948 and 1949. The Tax Court approved in principle, though its findings resulted in totals considerably less than those imposed by the Commissioner. The principal attack by Taxpayer is fourfold.…
2Cases cited29 opinions
- Holland v. United StatesSupreme Court of the United States · 1955
- Halle v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1949
- The John G. StevensSupreme Court of the United States · 1898
- Marsh v. Illinois Cent. R. Co.Court of Appeals for the Fifth Circuit · 1949
- Vincent Cefalu and Frances P. Cefalu v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1960
24 more not listed; retrieve them via the Exa API.
3Cited by17 opinions
- Frank J. Hradesky v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1976
- Monteleone v. CommissionerUnited States Tax Court · 1960
- Thomas W. Banks v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1963
- Estate of Upshaw v. CommissionerCourt of Appeals for the Seventh Circuit · 1969
- Harry and Amanda Schroeder v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1961
12 more not listed; retrieve them via the Exa API.