Parsons v. Commissioner
United States Tax Court
1. Petitioner omitted a variety of specific items of income from his separate individual income tax returns for the years 1943-47. Held, the returns were false and fraudulent with intent to evade tax and part of the deficiency for each year was due to fraud. 2. For each year in issue, the Commissioner had determined the amount of deficiency by a net worth statement involving the joint increases in net worth of both petitioner and his wife.
Read the full summary
1. Petitioner omitted a variety of specific items of income from his separate individual income tax returns for the years 1943-47. Held, the returns were false and fraudulent with intent to evade tax and part of the deficiency for each year was due to fraud. 2. For each year in issue, the Commissioner had determined the amount of deficiency by a net worth statement involving the joint increases in net worth of both petitioner and his wife. Held, the record in this case does not support any allocation of such increases to petitioner alone that would exceed the omissions found in respect of the…
1Opinion of the Court
FORRESTER, Judge:
Respondent determined deficiencies in income taxes and additions to tax as follows:1
Taxable year
Deficiency
Additions to tax
Sec. 293(b)
Sec. 294(d)(1)(B)
1943. $52,610.42 $28,013.82
1944. 72,179.31 42,077.46
1945. 64,041.32 27,020.66
1946. 63,669.78 31,784.89 $118.10
1947. 76,660.93 41,157.43
These determinations related to timely filed returns for said years, each of which bore the caption “William H. Parsons” and was signed only by William H. Parsons as the taxpayer making such return.
The statutory notice of deficiency setting out and explaining the determinations, which was mailed…
2Cases cited36 opinions
- Holland v. United StatesSupreme Court of the United States · 1955
- United States v. PowellSupreme Court of the United States · 1964
- Helvering v. TaylorSupreme Court of the United States · 1935
- Nat Harrison Assoc., Inc. v. CommissionerUnited States Tax Court · 1964
- Goe v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1952
31 more not listed; retrieve them via the Exa API.
3Cited by34 opinions
- Stratton v. CommissionerUnited States Tax Court · 1970
- Intervest Enterprises, Inc. v. CommissionerUnited States Tax Court · 1972
- Estate of Molever v. CommissionerUnited States Tax Court · 1992
- Gerardo v. CommissionerUnited States Tax Court · 1975
- Whyte v. CommissionerUnited States Tax Court · 1986
29 more not listed; retrieve them via the Exa API.