Lias v. Commissioner
United States Tax Court
On the facts, held: 1. Petitioner's net income for the taxable years in question was properly computed on the net worth expenditures basis. 2. The 50 per cent addition to the tax for fraud in each of the taxable years 1942 to 1948, inclusive, approved. 3. The 6 per cent penalty for substantial understatement of tax in petitioner's declaration of estimated tax for the years 1943 to 1947, inclusive, approved. 4. Petitioner owned certain bank accounts in the names of his wife…
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On the facts, held: 1. Petitioner's net income for the taxable years in question was properly computed on the net worth expenditures basis. 2. The 50 per cent addition to the tax for fraud in each of the taxable years 1942 to 1948, inclusive, approved. 3. The 6 per cent penalty for substantial understatement of tax in petitioner's declaration of estimated tax for the years 1943 to 1947, inclusive, approved. 4. Petitioner owned certain bank accounts in the names of his wife and children, and the interest thereon is taxable to him in the years 1944 and 1945. 5. The rents from two properties…
1Opinion of the Court
OPINION.
LeMiRe, Judge:
These proceedings involve income taxes and penalties of the petitioner for the years 1942 to 1947, inclusive, and of the petitioner and his wife for the year 1948, in the aggregate amount of $2,012,222.18. The deficiencies were determined by the respondent under the net worth expenditures method, the use of which is approved by the Supreme Court in cases of the character here under scrutiny. Holland v. United States, 348 U. S. 121.
Before discussing the specific issues presented, a brief summary of the petitioner’s background and activities prior to the taxable years is…
2Cases cited7 opinions
- Holland v. United StatesSupreme Court of the United States · 1955
- Helvering v. MitchellSupreme Court of the United States · 1938
- Howell v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1949
- Samuel R. Beard v. United StatesCourt of Appeals for the Fourth Circuit · 1955
- Earl Kite v. Commissioner of Internal Revenue, Mary B. Kite v. Commissioner or Internal RevenueCourt of Appeals for the Fifth Circuit · 1955
2 more not listed; retrieve them via the Exa API.
3Cited by2 opinions
- United States v. LiasDistrict Court, N.D. West Virginia · 1955
- Lias v. CommissionerUnited States Tax Court · 1955