Legal Opinion

Sauer v. Commissioner

United States Tax Court

Decided August 30, 1965No. Docket No. 3120-63Unpublished

Held, petitioners failed to prove that $35,000 deposited in their bank account purportedly as the purchase price of stock in a corporation owned 50 percent by petitioners was not taxable income as determined by respondent. Held, further: Respondent failed to prove that any part of petitioners' underpayment of tax for 1956 was due to fraud. Addition to tax for fraud disallowed.

1Opinion of the Court

Carl Sauer and Alice Sauer a.k.a. Carl Saunders and Alice Saunders v. Commissioner.

Sauer v. Commissioner

Docket No. 3120-63.

United States Tax Court

T.C. Memo 1965-236; 1965 Tax Ct. Memo LEXIS 95; 24 T.C.M. (CCH) 1197; T.C.M. (RIA) 65236;

August 30, 1965

Held, petitioners failed to prove that $35,000 deposited in their bank account purportedly as the purchase price of stock in a corporation owned 50 percent by petitioners was not taxable income as determined by respondent. Held, further: Respondent failed to prove that any part of petitioners' underpayment of tax for 1956 was due to fraud.…

2Cases cited11 opinions

  1. James v. United StatesSupreme Court of the United States · 1961
  2. L. Schepp Co. v. CommissionerUnited States Board of Tax Appeals · 1932
  3. Muldrow v. CommissionerUnited States Tax Court · 1962
  4. Akers v. ScofieldCourt of Appeals for the Fifth Circuit · 1948
  5. Snell Isle, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1937

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