Legal Opinion

Estate of Iaconi v. Commissioner

United States Tax Court

Decided April 13, 1961No. Docket Nos. 39511, 39512Unpublished

Held: 1. Income of taxpayer determined by use of increase in net worth plus expenditures method. 2. Various properties acquired were purchased with funds owned by petitioner. 3. False and fraudulent returns with intent to evade tax were filed for all the taxable years, and part of each deficiency is due to fraud with intent to evade tax.

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Held: 1. Income of taxpayer determined by use of increase in net worth plus expenditures method. 2. Various properties acquired were purchased with funds owned by petitioner. 3. False and fraudulent returns with intent to evade tax were filed for all the taxable years, and part of each deficiency is due to fraud with intent to evade tax. Secs. 276(a) and 293(b). 4. The determinations of deficiencies for 1945, 1946, and 1947 are not barred, secs. 275(c), 276(a), 276(b); and jeopardy assessments of taxes and additions thereto for the same years under section 273(a) were not barred. 5. Additions…

1Opinion of the Court

Estate of Frank Iaconi, Deceased, Angelo J. Iaconi, Administrator v. Commissioner.

Estate of Iaconi v. Commissioner

Docket Nos. 39511, 39512.

United States Tax Court

T.C. Memo 1961-106; 1961 Tax Ct. Memo LEXIS 244; 20 T.C.M. (CCH) 502; T.C.M. (RIA) 61106;

April 13, 1961

Held: 1. Income of taxpayer determined by use of increase in net worth plus expenditures method.

2. Various properties acquired were purchased with funds owned by petitioner.

3. False and fraudulent returns with intent to evade tax were filed for all the taxable years, and part of each deficiency is due to fraud with intent to evade…

2Cases cited24 opinions

  1. Holland v. United StatesSupreme Court of the United States · 1955
  2. Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
  3. Smith v. United StatesSupreme Court of the United States · 1954
  4. United States v. JohnsonSupreme Court of the United States · 1943
  5. Commissioner v. AckerSupreme Court of the United States · 1959

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