Abraham v. Commissioner
United States Tax Court
Held: (1) Respondent's use of the net worth plus nondeductible expenditures method in reconstructing petitioners' net income for each of the years in issue was justified. (2) Petitioners realized net income in each of the years 1944 to 1953, inclusive, in excess of the amounts set forth in their income tax returns. (3) No part of the deficiency for any of the years involved was due to fraud with intent to evade tax.
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Held: (1) Respondent's use of the net worth plus nondeductible expenditures method in reconstructing petitioners' net income for each of the years in issue was justified. (2) Petitioners realized net income in each of the years 1944 to 1953, inclusive, in excess of the amounts set forth in their income tax returns. (3) No part of the deficiency for any of the years involved was due to fraud with intent to evade tax. (4) The assessment and collection of the deficiencies and additions to tax for each of the years 1944 to 1951, inclusive, are barred by limitations. (5) Petitioners substantially…
1Opinion of the Court
Edwin Abraham v. Commissioner. Edwin Abraham and Daisy E. Abraham v. Commissioner.
Abraham v. Commissioner
Docket Nos. 76349, 76389.
United States Tax Court
T.C. Memo 1962-160; 1962 Tax Ct. Memo LEXIS 149; 21 T.C.M. (CCH) 882; T.C.M. (RIA) 62160;
June 28, 1962
Held: (1) Respondent's use of the net worth plus nondeductible expenditures method in reconstructing petitioners' net income for each of the years in issue was justified.(2) Petitioners realized net income in each of the years 1944 to 1953, inclusive, in excess of the amounts set forth in their income tax returns.(3) No part of the deficiency…
2Cases cited22 opinions
- Holland v. United StatesSupreme Court of the United States · 1955
- Mitchell v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1941
- William J. Drieborg and Laura D. Drieborg v. Commissioner of Internal Revenue, William J. Drieborg v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1955
- Rogers v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1940
- George Schwarzkopf v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1957
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