Napuche v. Comm'r
United States Tax Court
Held, respondent properly reconstructed petitioner's net income for the years 1946-1951, inclusive, by the use of the net worth plus nondeductible expenditures method, and the deficiencies determined thereby are sustained.
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Held, respondent properly reconstructed petitioner's net income for the years 1946-1951, inclusive, by the use of the net worth plus nondeductible expenditures method, and the deficiencies determined thereby are sustained. Held, further, a part of the deficiency for each of the years 1946 through 1951 was due to fraud with intent to evade tax; the returns for the years 1946, 1947, and 1950 were false and fraudulent with intent to evade tax; and the assessment and collection of deficiencies for the years 1946, 1947, and 1950 are not barred by the statute of limitations. Held, further,…
1Opinion of the Court
Christo P. Napuche v. Commissioner.
Napuche v. Comm'r
Docket No. 62078.
United States Tax Court
T.C. Memo 1959-112; 1959 Tax Ct. Memo LEXIS 136; 18 T.C.M. (CCH) 505; T.C.M. (RIA) 59112;
May 28, 1959
Held, respondent properly reconstructed petitioner's net income for the years 1946-1951, inclusive, by the use of the net worth plus nondeductible expenditures method, and the deficiencies determined thereby are sustained. Held, further, a part of the deficiency for each of the years 1946 through 1951 was due to fraud with intent to evade tax; the returns for the years 1946, 1947, and 1950 were false…
2Cases cited5 opinions
- Gano v. CommissionerUnited States Board of Tax Appeals · 1930
- Kilpatrick v. CommissionerUnited States Tax Court · 1954
- Henry Watterson Hotel Co. v. CommissionerUnited States Tax Court · 1950
- Smith v. CommissionerUnited States Tax Court · 1958
- LeFiell v. CommissionerUnited States Tax Court · 1953