Legal Opinion

Vaughn v. Commissioner

United States Tax Court

Decided December 8, 1986No. Docket No. 33011-83Unpublished

Ps, who operated a general contracting business, reported their business income using the cash method of accounting.During 1976, 1977, and 1978, Ps deposited some business receipts into their personal savings accounts or used some business receipts to purchase certificates of deposit. Such receipts were not reported as income in the year received.

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Ps, who operated a general contracting business, reported their business income using the cash method of accounting.During 1976, 1977, and 1978, Ps deposited some business receipts into their personal savings accounts or used some business receipts to purchase certificates of deposit. Such receipts were not reported as income in the year received. The Commissioner discovered this unreported income and determined deficiencies and additions to tax for fraud under sec. 6653(b), I.R.C. 1954. Held: (1) Ps conduct with respect to such unreported income did not rise to the level of intentional…

1Opinion of the Court

WENDELL W. and LIDA D. VAUGHN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Vaughn v. Commissioner

Docket No. 33011-83.

United States Tax Court

T.C. Memo 1986-578; 1986 Tax Ct. Memo LEXIS 29; 52 T.C.M. (CCH) 1133; T.C.M. (RIA) 86578;

December 8, 1986.

Ps, who operated a general contracting business, reported their business income using the cash method of accounting.During 1976, 1977, and 1978, Ps deposited some business receipts into their personal savings accounts or used some business receipts to purchase certificates of deposit. Such receipts were not reported as income in the…

2Cases cited27 opinions

  1. Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
  2. Spies v. United StatesSupreme Court of the United States · 1943
  3. Rowlee v. CommissionerUnited States Tax Court · 1983
  4. Gajewski v. CommissionerUnited States Tax Court · 1976
  5. Beaver v. CommissionerUnited States Tax Court · 1970

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