Bien v. Commissioner
United States Tax Court
1. Were the petitioners computed their net income upon the basis of the "hybrid" method of accounting regularly employed in keeping their books, held, the method employed does not clearly reflect income and the determination of the respondent is sustained. 2. Where petitioners failed to produce any evidence to substantiate their claimed deduction for expenses incurred in connection with the rental of a portion of their residence, held, the petitioners have failed in their…
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1. Were the petitioners computed their net income upon the basis of the "hybrid" method of accounting regularly employed in keeping their books, held, the method employed does not clearly reflect income and the determination of the respondent is sustained. 2. Where petitioners failed to produce any evidence to substantiate their claimed deduction for expenses incurred in connection with the rental of a portion of their residence, held, the petitioners have failed in their burden of proof and the determination of the respondent is sustained. 3. Where petitioners incurred expenses in connection…
1Opinion of the Court
V. T. H. Bien and Bertha C. Bien, Petitioners, v. Commissioner of Internal Revenue, Respondent
Bien v. Commissioner
Docket No. 33872
United States Tax Court
20 T.C. 49; 1953 U.S. Tax Ct. LEXIS 198;
April 10, 1953, Promulgated
Decision will be entered under Rule 50.
1. Were the petitioners computed their net income upon the basis of the "hybrid" method of accounting regularly employed in keeping their books, held, the method employed does not clearly reflect income and the determination of the respondent is sustained.
2. Where petitioners failed to produce any evidence to substantiate their claimed…
2Cases cited8 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Brown v. HelveringSupreme Court of the United States · 1934
- Stern Bros. & Co. v. CommissionerUnited States Tax Court · 1951
- Hygienic Products Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1940
- Bien v. CommissionerUnited States Tax Court · 1953
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