Legal Opinion

Bushnell v. Commissioner

United States Tax Court

Decided December 29, 1967No. Docket No. 2264-65Published

1. Held, that for each of the taxable years 1949 through 1958 the husband-petitioner received taxable income which was not reported in the joint income tax return filed by him and his wife.

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1. Held, that for each of the taxable years 1949 through 1958 the husband-petitioner received taxable income which was not reported in the joint income tax return filed by him and his wife. Amounts of such unreported income are determined on the basis of said petitioner's admissions and of entries in his books and records, rather than by respondent's net worth computations. 2. Held, that at least part of the deficiency for each of the years involved is due to fraud with intent to evade tax. 3. Held, that there was a substantial underestimate of estimated income tax for each of the years 1950…

1Opinion of the Court

Lowell F. Bushnell and Dorothy C. Bushnell, Petitioners v. Commissioner of Internal Revenue, Respondent

Bushnell v. Commissioner

Docket No. 2264-65

United States Tax Court

49 T.C. 296; 1967 U.S. Tax Ct. LEXIS 2;

December 29, 1967, Filed

Decision will be entered under Rule 50.

1. Held, that for each of the taxable years 1949 through 1958 the husband-petitioner received taxable income which was not reported in the joint income tax return filed by him and his wife. Amounts of such unreported income are determined on the basis of said petitioner's admissions and of entries in his books and records,…

Also in this document: Concurrence · Raum; Concurrence · Dawson; Dissent.

2Cases cited2 opinions

  1. Bartlett v. CommissionerUnited States Tax Court · 1954
  2. Bushnell v. CommissionerUnited States Tax Court · 1967

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