Willits v. Commissioner
United States Board of Tax Appeals
Petitioner, an internal revenue agent, prepared income tax returns for certain taxpayers. In his own income tax returns for the same years, he reported no income for the services rendered.
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Petitioner, an internal revenue agent, prepared income tax returns for certain taxpayers. In his own income tax returns for the same years, he reported no income for the services rendered. Upon investigation by a special agent for the Bureau of Internal Revenue it was discovered that the taxpayers for whom petitioner had rendered service had made large payments of money directly to petitioner and to petitioner's mother-in-law, which were deposited in an account in the name of the mother-in-law and quickly withdrawn in favor of petitioner. Faced with these facts, petitioner resigned his…
1Opinion of the Court
*296OPINION.
Miller:(1) The first question presented is whether additional income was received which was not disclosed by the taxpayer. Upon this issue the determination of the respondent is prima facie correct. Burnet v. Houston, 283 U. S. 223; Welsh v. Helvering, 290 U. S. 111; *297Reinecke v. Spalding, 280 U. S. 227, 233; United States v. Anderson, 269 U. S. 422, 443; Botany Worsted Mills v. United States, 278 U. S. 282, 289, 290; Wickwire v. Reinecke, 275 U. S. 101; Old Mission Portland Cement Co. v. Helvering, 293 U. S. 289. The burden was upon the petitioner to overcome the presumption of…
2Cases cited7 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- United States v. AndersonSupreme Court of the United States · 1926
- Botany Worsted Mills v. United StatesSupreme Court of the United States · 1929
- Burnet v. HoustonSupreme Court of the United States · 1931
- Wickwire v. ReineckeSupreme Court of the United States · 1927
2 more not listed; retrieve them via the Exa API.
3Cited by35 opinions
- Ethel A. Doll v. Seldon R. GlennCourt of Appeals for the Sixth Circuit · 1956
- Klein v. CommissionerUnited States Tax Court · 1965
- Harris v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1949
- Spitaleri v. CommissionerUnited States Tax Court · 1959
- Estate of Granat v. CommissionerUnited States Tax Court · 1960
30 more not listed; retrieve them via the Exa API.