Calafato v. Commissioner
United States Board of Tax Appeals
Petitioners, husband and wife, filed no returns of income for several years. In 1933 a joint return was filed. The respondent determined that they had received substantial amounts of income, some of which had been deposited in accounts standing in the name of one or both, and that there had been a commingling of funds and payment of the obligations of one out of the account of another.
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Petitioners, husband and wife, filed no returns of income for several years. In 1933 a joint return was filed. The respondent determined that they had received substantial amounts of income, some of which had been deposited in accounts standing in the name of one or both, and that there had been a commingling of funds and payment of the obligations of one out of the account of another. Being unable to secure any information from the petitioners as to the source and ownership of such funds, he mailed one deficiency notice to both of them. Petitioners joined in a petition to this Board for a…
1Opinion of the Court
OPINION.
Mellott:
On February 19, 1938, the Commissioner determined a “deficiency in income tax, penalty and interest amounting to $23,560.13 for the taxable years ended December 31, 1929, 1930 and 1931.” The notice was addressed to “Mr. Joseph Calafato, Mrs. Lena Calafato, *882Husband, and Wife, 1611 Chestnut Street, Erie, Pennsylvania.” The statement attached allocated the amounts to tax and penalties as shown in the schedule below, the balance being interest:
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Petition asking for a redetermination of the deficiency was filed with the Board on May 19, 1938, and docketed as No. 93617.…
2Cases cited1 opinion
- Helvering v. TaylorSupreme Court of the United States · 1935
3Cited by30 opinions
- Estate of Mason v. CommissionerUnited States Tax Court · 1975
- Estate of Beck v. Comm'rUnited States Tax Court · 1971
- Goe v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1952
- Parsons v. CommissionerUnited States Tax Court · 1964
- Harris v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1949
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