Bushnell v. Commissioner
United States Tax Court
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
OPINION
I. Re Issue 1
The first issue to be decided requires answers to two related questions, to wit: Did the petitioner, during each of the 10 years involved, receive taxable income which he did not report in the joint income tax return filed by him and his wife? And (2), if he did, what are the amounts of such unreported income ?
The answers to these questions are basic to the decision of all issues here involved — because the validity of all the deficiencies and other liabilities which the respondent determined in his notice of deficiencies, and also the validity of all the differing…
2Cases cited4 opinions
- Holland v. United StatesSupreme Court of the United States · 1955
- Reuben G. Lenske v. United StatesCourt of Appeals for the Ninth Circuit · 1967
- Talley v. CommissionerUnited States Tax Court · 1953
- Ragsdale v. PaschalDistrict Court, E.D. Arkansas · 1954
3Cited by17 opinions
- Slawek v. CommissionerUnited States Tax Court · 1987
- Estate of Goodwyn v. CommissionerUnited States Tax Court · 1973
- Beyer v. CommissionerUnited States Tax Court · 1988
- Bushnell v. CommissionerUnited States Tax Court · 1967
- Carpenter Family Investments, LLC, Carpenter Capital Management, LLC, Tax Matters Partner v. CommissionerUnited States Tax Court · 2011
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