Legal Opinion

Estate of Mason v. Commissioner

United States Tax Court

Decided July 28, 1975No. Docket No. 4473-70Published

1. Deposits in petitioners' savings and checking accounts far exceeded their reported income. They kept no books or records of their income, and when an internal revenue agent investigated their returns, they failed to give any plausible explanation for the large amount of deposits. An explanation, offered for the first time at trial, indicated that some of the deposits were not income, and thereupon the Commissioner so conceded.

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1. Deposits in petitioners' savings and checking accounts far exceeded their reported income. They kept no books or records of their income, and when an internal revenue agent investigated their returns, they failed to give any plausible explanation for the large amount of deposits. An explanation, offered for the first time at trial, indicated that some of the deposits were not income, and thereupon the Commissioner so conceded. Held, the Commissioner's determination to reconstruct their income by the bank deposit method was not arbitrary or unreasonable; held, further, the explanation…

1Opinion of the Court

Estate of Mary Mason, Deceased, Herbert L. Harris, Administrator, and Robert Mason, Petitioners v. Commissioner of Internal Revenue, Respondent

Estate of Mason v. Commissioner

Docket No. 4473-70

United States Tax Court

64 T.C. 651; 1975 U.S. Tax Ct. LEXIS 102;

July 28, 1975, Filed

Decision will be entered under Rule 155.

1. Deposits in petitioners' savings and checking accounts far exceeded their reported income. They kept no books or records of their income, and when an internal revenue agent investigated their returns, they failed to give any plausible explanation for the large amount of deposits.…

2Cases cited40 opinions

  1. Helvering v. TaylorSupreme Court of the United States · 1935
  2. Bixby v. CommissionerUnited States Tax Court · 1972
  3. Roberts v. CommissionerUnited States Tax Court · 1974
  4. Halle v. CommissionerUnited States Tax Court · 1946
  5. Halle v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1949

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