Legal Opinion

Kuhl v. Commissioner

United States Tax Court

Decided August 2, 1993No. Docket Nos. 14202-91, 30602-91Unpublished

This case pertains to the qualification and substantiation of costs of goods sold and certain deductions claimed on P's 1985, 1987, 1988, and 1989 Federal income tax returns.

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This case pertains to the qualification and substantiation of costs of goods sold and certain deductions claimed on P's 1985, 1987, 1988, and 1989 Federal income tax returns. Respondent also increased P's taxable income for unreported interest and dividend income for the 1988 taxable year, and unreported dividend income for the 1989 taxable year, and determined additions to tax for: (1) Untimely filed tax returns for all the years in issue, and (2) substantial understatements of income tax for the 1985, 1987, and 1988 taxable years. Held: P failed to substantiate his claimed deductions and…

1Opinion of the Court

JAMES A. KUHL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Kuhl v. Commissioner

Docket Nos. 14202-91, 30602-91

United States Tax Court

T.C. Memo 1993-338; 1993 Tax Ct. Memo LEXIS 342; 66 T.C.M. (CCH) 278;

August 2, 1993, Filed

Decisions will be entered for respondent.

This case pertains to the qualification and substantiation of costs of goods sold and certain deductions claimed on P's 1985, 1987, 1988, and 1989 Federal income tax returns. Respondent also increased P's taxable income for unreported interest and dividend income for the 1988 taxable year, and unreported dividend income…

2Cases cited13 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
  3. Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
  4. United States v. GilmoreSupreme Court of the United States · 1963
  5. Sanford v. CommissionerUnited States Tax Court · 1968

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