Beaver v. Commissioner
United States Tax Court
1. Held, that advances received by the petitioner from his employer constituted payments for services to be rendered in the future, rather than loans, and that such advances constituted taxable income to the petitioner in the years received. 2. Held, further, that some part of the underpayment of tax required to be shown on petitioners' return for each of the taxable years 1956 through 1962 was due to fraud with intent to evade tax and that petitioners are therefore liable…
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1. Held, that advances received by the petitioner from his employer constituted payments for services to be rendered in the future, rather than loans, and that such advances constituted taxable income to the petitioner in the years received. 2. Held, further, that some part of the underpayment of tax required to be shown on petitioners' return for each of the taxable years 1956 through 1962 was due to fraud with intent to evade tax and that petitioners are therefore liable for additions to tax under sec. 6653(b), I.R.C. 1954.
1Opinion of the Court
Atkins, Judge:
The respondent determined deficiencies in income tax for the taxable years 1956 through 1962 and additions to tax as follows:
Year Addition to tax under Deficiency see. 6668Q>)
1956 $118. 48 $122. 24
1957 _ 566. 81
1958 175. 00 1, 743. 38
1959 1, 249. 53 2, 408. 63
1960 1, 574. 31 3, 209. 48
1961 189. 03 2, 810. 63
1962 185. 38 3, 318. 36
The petitioners having conceded one issue, the issues remaining for decision are whether certain advances received by the petitioner Anson Beaver from his employer constituted taxable compensation or loans and whether any part of any underpayment of tax…
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