Edward J. Holland, Jr. v. Commissioner of Internal Revenue

This is an appeal from a decision of the United States Tax Court redetermining the income tax deficiency and determining additions to the tax liability of petitioner-appellant Edward J. Holland, Jr. The Tax Court’s opinion is published at Holland v. Commissioner, 51 T.C.M. (CCH) 172 (1985).

On July 14, 1982 the Internal Revenue Service sent Holland a notice of deficiency for the 1977 and 1978 tax years disallowing a number of claimed deductions. The deficiency was assessed on the basis of Holland’s failure to prove that the transactions alleged in those deductions ever occurred. Holland then…