Libutti v. Comm'r
United States Tax Court
Held, Ps failed to report all of their income from recing activities and sale of thoroughbred horses; Held further, Ps business expenses determined with respect to the taxable years 1969 through 1971; Held further, Ps are not entitled to a claimed bad debt loss and theft loss in 1971; Held further, fraud not proven with respect to Petitioner Robert LiButti for taxable years 1968 and 1969; Held further, fraud proven with respect to Petitioner Robert LiButti for the taxable…
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Held, Ps failed to report all of their income from recing activities and sale of thoroughbred horses; Held further, Ps business expenses determined with respect to the taxable years 1969 through 1971; Held further, Ps are not entitled to a claimed bad debt loss and theft loss in 1971; Held further, fraud not proven with respect to Petitioner Robert LiButti for taxable years 1968 and 1969; Held further, fraud proven with respect to Petitioner Robert LiButti for the taxable years 1970 and 1971; Held further fraud not proven with respect to Petitioner Joan LiButti for the taxable years 1968…
1Opinion of the Court
ROBERT LiBUTTI a/k/a ROBERT PRESTI AND JOAN LiBUTTI a/k/a JOAN PRESTI, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Libutti v. Comm'r
Docket Nos. 5977-75, 6289-77, 547-79.
United States Tax Court
T.C. Memo 1985-314; 1985 Tax Ct. Memo LEXIS 318; 50 T.C.M. (CCH) 241;
June 26, 1985.
Held, Ps failed to report all of their income from recing activities and sale of thoroughbred horses; Held further, Ps business expenses determined with respect to the taxable years 1969 through 1971; Held further, Ps are not entitled to a claimed bad debt loss and theft loss in 1971; Held further, fraud not…
2Cases cited86 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Holland v. United StatesSupreme Court of the United States · 1955
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
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