Senyszyn v. Comm'r
United States Tax Court
Between 2002 and 2004, PH misappropriated funds from a business associate, DH. As part of a criminal investigation of PH, a revenue agent examined records of accounts belonging to Ps, DH, or related entities and determined that, during 2003, PH received from DH's accounts $252,726 more than he paid back to DH during that year.
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Between 2002 and 2004, PH misappropriated funds from a business associate, DH. As part of a criminal investigation of PH, a revenue agent examined records of accounts belonging to Ps, DH, or related entities and determined that, during 2003, PH received from DH's accounts $252,726 more than he paid back to DH during that year. PH later pleaded guilty to and was convicted of criminal charges, including tax evasion in violation of I.R.C. sec. 7201. Under a plea agreement, PH agreed to a stipulation that he knowingly and willfully failed to report $252,726 of taxable income for 2003. Held: The…
1Opinion of the Court
BOHDAN SENYSZYN AND KELLY L. SENYSZYN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Senyszyn v. Comm'r
Docket No. 9721-11
United States Tax Court
146 T.C. 136; 2016 U.S. Tax Ct. LEXIS 10; 146 T.C. No. 9;
March 31, 2016, Filed
Senyszyn v. Comm'r, T.C. Memo 2013-274, 2013 Tax Ct. Memo LEXIS 283 (T.C., 2013)
Decision will be entered for petitioners.
Between 2002 and 2004, PH misappropriated funds from a business associate, DH. As part of a criminal investigation of PH, a revenue agent examined records of accounts belonging to Ps, DH, or related entities and determined that, during 2003,…
2Cases cited23 opinions
- Parklane Hosiery Co. v. ShoreSupreme Court of the United States · 1979
- Montana v. United StatesSupreme Court of the United States · 1979
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Old Colony Trust Co. v. CommissionerSupreme Court of the United States · 1929
- Sansone v. United StatesSupreme Court of the United States · 1965
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