Joseph L. Friedman v. Commissioner of Internal Revenue

This is an appeal from a redetermination by the Tax Court that the appellant, Joseph L. Friedman, a physician, is liable for additional income tax for the years 1956 through 1962, and that he is also liable for the fraud penalty for these years. This redetermination by the Tax Court resulted from a trial in which the Commissioner relied upon net worth computations to show that the appellant had substantially understated his income during the years in question.

It is the appellant’s contention that his starting net worth was not correctly established because the amount of cash on hand for which…