Legal Opinion

Sunbrock v. Commissioner

United States Tax Court

Decided April 25, 1967No. Docket Nos. 54080, 54081, 54159, 55241PublishedCited by 32 opinions

Respondent's determinations of deficiencies in income tax, based on increase in net worth, and additions to tax for fraud under sec. 293(b), I.R.C. 1939, sustained with certain adjustments, where petitioner failed to keep adequate records of his business and omitted large amounts of income from his returns.

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Respondent's determinations of deficiencies in income tax, based on increase in net worth, and additions to tax for fraud under sec. 293(b), I.R.C. 1939, sustained with certain adjustments, where petitioner failed to keep adequate records of his business and omitted large amounts of income from his returns. Additions to tax under sec. 291(a) for delinquent filing and sec. 294(d)(1)(A) for failure to file declarations of estimated tax sustained in the absence of proof of reasonable cause.

1Opinion of the Court

Beuge, Judge:

Respondent determined deficiencies in income tax and additions to tax under sections 293 (b), 291(a), and 294(d) (1) (A) of the Internal Revenue Code of 1939, for the years 1947, 1949, 1950, and 1951, as follows:

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Respondent also determined additions to tax under section 294(d) (2) of the Internal Revenue Code of 1939 for substantial underestimate of estimated tax for each of the years in question. At the' hearing and on brief, respondent has conceded that petitioners are not liable for the additions to tax imposed by section 294(d) (2) in view of the Supreme Court’s…

2Cases cited20 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Holland v. United StatesSupreme Court of the United States · 1955
  3. Commissioner v. SunnenSupreme Court of the United States · 1948
  4. Commissioner v. AckerSupreme Court of the United States · 1959
  5. Condor Merritt v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1962

15 more not listed; retrieve them via the Exa API.

3Cited by32 opinions

  1. Otsuki v. CommissionerUnited States Tax Court · 1969
  2. Joseph Solomon v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1984
  3. Stratton v. CommissionerUnited States Tax Court · 1970
  4. Mazzoni v. CommissionerUnited States Tax Court · 1970
  5. Tunnell v. CommissionerUnited States Tax Court · 1980

27 more not listed; retrieve them via the Exa API.

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