Legal Opinion

Kofmehl v. Commissioner

United States Tax Court

Decided November 6, 1978No. Docket No. 8845-74Unpublished

Held: On these facts, where books and records maintained by taxpayer were inadequate, respondent was justified in reconstructing petitioner's income using cash basis net worth method notwithstanding the existence of inventories of petitioner. Thus, deficiencies were properly determined. Held further: The additions to tax under sec. 6653(b), I.R.C. 1954, denied for 1967, and upheld for 1968 and 1969.

1Opinion of the Court

PATRICK H. KOFMEHL AND LINDA M. KOFMEHL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Kofmehl v. Commissioner

Docket No. 8845-74.

United States Tax Court

T.C. Memo 1978-439; 1978 Tax Ct. Memo LEXIS 70; 37 T.C.M. (CCH) 1831; T.C.M. (RIA) 78439;

November 6, 1978, Filed

Held: On these facts, where books and records maintained by taxpayer were inadequate, respondent was justified in reconstructing petitioner's income using cash basis net worth method notwithstanding the existence of inventories of petitioner. Thus, deficiencies were properly determined. Held further: The additions to tax…

2Cases cited24 opinions

  1. Holland v. United StatesSupreme Court of the United States · 1955
  2. Gajewski v. CommissionerUnited States Tax Court · 1976
  3. Ullman v. CommissionerCourt of Appeals for the Second Circuit · 1959
  4. Imburgia v. CommissionerUnited States Tax Court · 1954
  5. Estate of Temple v. CommissionerUnited States Tax Court · 1976

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