Llorente v. Commissioner
United States Tax Court
Based upon information furnished to an undercover agent by an informant and the agent's personal knowledge, respondent determined that petitioner purchased cocaine during 1974. Held: Sufficient evidence introduced to render statutory notice not arbitrary and excessive. Jackson v. Commissioner, 73 T.C. 394 (1979), and Weimerskirch v. Commissioner, 596 F.2d 358 (9th Cir. 1979), revg. 67 T.C. 672 (1977), distinguished. Taxable income determined under the expenditures method.
Read the full summary
Based upon information furnished to an undercover agent by an informant and the agent's personal knowledge, respondent determined that petitioner purchased cocaine during 1974. Held: Sufficient evidence introduced to render statutory notice not arbitrary and excessive. Jackson v. Commissioner, 73 T.C. 394 (1979), and Weimerskirch v. Commissioner, 596 F.2d 358 (9th Cir. 1979), revg. 67 T.C. 672 (1977), distinguished. Taxable income determined under the expenditures method. Held, further, dependency exemption deduction determined.
1Opinion of the Court
Raul Llorente, Petitioner v. Commissioner of Internal Revenue, Respondent
Llorente v. Commissioner
Docket No. 10962-76
United States Tax Court
74 T.C. 260; 1980 U.S. Tax Ct. LEXIS 138; 74 T.C. No. 20;
May 13, 1980, Filed
Decision will be entered under Rule 155.
Based upon information furnished to an undercover agent by an informant and the agent's personal knowledge, respondent determined that petitioner purchased cocaine during 1974. Held: Sufficient evidence introduced to render statutory notice not arbitrary and excessive. Jackson v. Commissioner, 73 T.C. 394 (1979), and Weimerskirch v.…
Also in this document: Concurrence · Fay; Concurrence · Tannenwald; Dissent.
2Cases cited56 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- United States v. JanisSupreme Court of the United States · 1976
- Helvering v. TaylorSupreme Court of the United States · 1935
- Wichita Term. El. Co. v. Commissioner of Int. R.Court of Appeals for the Tenth Circuit · 1947
51 more not listed; retrieve them via the Exa API.