Rogers v. Commissioner
United States Board of Tax Appeals
FRAUD PENALTIES - JOINT AND SEVERAL LIABILITY. - Petitioners filed joint income tax returns for the years 1932, 1933, and 1934, in which they reported less than one-half of the net income admitted to have been received by them from legitimate sources. Each received taxable income in a substantial but undisclosed amount.
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FRAUD PENALTIES - JOINT AND SEVERAL LIABILITY. - Petitioners filed joint income tax returns for the years 1932, 1933, and 1934, in which they reported less than one-half of the net income admitted to have been received by them from legitimate sources. Each received taxable income in a substantial but undisclosed amount. Respondent determined deficiencies on the basis of bank deposits and unexplained credits to the accounts of petitioners on the books of a corporation, plus fraud penalties. On the evidence, held, that the deficiencies are due to fraud with intent to evade tax, and petitioners…
1Opinion of the Court
*20OPINION.
Hill:
In computing the deficiency for 1932 respondent added to the net income reported by petitioners certain credits to their accounts on the books of the M & R Canning Co. in the amount of $17,080.30, and in computing the deficiency for 1933 respondent added to the reported net income credits to petitioners’ accounts on the books of the Canning Co. plus bank deposits, in the total amount of $65,072.40. Respondent likewise made a number of other adjustments to net income for both years, which are not in controversy here. Petitioners concede that all amounts added to income by…
2Cited by81 opinions
- Stone v. CommissionerUnited States Tax Court · 1971
- Rogers v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1940
- Farber v. CommissionerUnited States Tax Court · 1965
- Smith v. CommissionerUnited States Tax Court · 1959
- Mazzoni v. CommissionerUnited States Tax Court · 1970
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