John W. Snow, Jr. v. Commissioner
United States Tax Court
Respondent reconstructed petitioner's income by the increase in net worth method and determined deficiences and negligence penalties for 1946, 1947, and 1948. Held: 1. Respondent's use of the net worth method was proper and not arbitrary. 2. On the record, a cash sum in excess of $20,000 was earned during 1946, 1947, and 1948 and did not, as petitioner contended, constitute fire insurance proceeds collected by him in 1931 and held in his daughter's safe deposit box. 3. The…
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Respondent reconstructed petitioner's income by the increase in net worth method and determined deficiences and negligence penalties for 1946, 1947, and 1948. Held: 1. Respondent's use of the net worth method was proper and not arbitrary. 2. On the record, a cash sum in excess of $20,000 was earned during 1946, 1947, and 1948 and did not, as petitioner contended, constitute fire insurance proceeds collected by him in 1931 and held in his daughter's safe deposit box. 3. The gain realized on the trade-in of a Ford was nonrecognizable under Sec. 112(b)(1), I.R.C., because derived from exchange…
1Opinion of the Court
John W. Snow, Jr. v. Commissioner.
John W. Snow, Jr. v. Commissioner
Docket No. 30121.
United States Tax Court
1953 Tax Ct. Memo LEXIS 64; 12 T.C.M. (CCH) 1281; T.C.M. (RIA) 53358;
November 10, 1953
Respondent reconstructed petitioner's income by the increase in net worth method and determined deficiences and negligence penalties for 1946, 1947, and 1948. Held:
1. Respondent's use of the net worth method was proper and not arbitrary.
2. On the record, a cash sum in excess of $20,000 was earned during 1946, 1947, and 1948 and did not, as petitioner contended, constitute fire insurance proceeds…
2Cases cited16 opinions
- Helvering v. TaylorSupreme Court of the United States · 1935
- Burnet v. HoustonSupreme Court of the United States · 1931
- Halle v. CommissionerUnited States Tax Court · 1946
- Chipley v. CommissionerUnited States Board of Tax Appeals · 1932
- Solt v. CommissionerUnited States Tax Court · 1952
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