Petzoldt v. Commissioner
United States Tax Court
In May 1984, P was arrested for speeding in Florida. The arresting officer found $ 610,712.42 in cash in the automobile P was driving, as well as some marijuana, two controlled substances, drug paraphernalia, and P's passport. P claimed ownership of the cash.
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In May 1984, P was arrested for speeding in Florida. The arresting officer found $ 610,712.42 in cash in the automobile P was driving, as well as some marijuana, two controlled substances, drug paraphernalia, and P's passport. P claimed ownership of the cash. P further, through certain "drug ledgers," was linked with drug purchases totaling $ 3,053,430 made in 1983 and 1984. Using the cash-expenditures method of income reconstruction, R determined that P had unreported income from drug trafficking for 1983 in the amount of the drug purchases, and for 1984 in the amount of the drug purchases,…
1Opinion of the Court
Charles Petzoldt, Petitioner v. Commissioner of Internal Revenue, Respondent
Petzoldt v. Commissioner
Docket Nos. 34853-84, 34408-85
United States Tax Court
92 T.C. 661; 1989 U.S. Tax Ct. LEXIS 42; 92 T.C. No. 37;
March 29, 1989; As amended April 12, 1989 March 29, 1989, Filed
Decisions will be entered for the respondent.
In May 1984, P was arrested for speeding in Florida. The arresting officer found $ 610,712.42 in cash in the automobile P was driving, as well as some marijuana, two controlled substances, drug paraphernalia, and P's passport. P claimed ownership of the cash. P further, through…
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