Legal Opinion

Durovic v. Commissioner

United States Tax Court

Decided June 24, 1970No. Docket No. 1633-65Published

1. Held, the good-faith filing of a Form 1065 partnership return reflecting petitioner's only source of income was not sufficient to start the running of the statute of limitations where petitioner had failed to file an individual return, as required by sec. 6012(a). 2. Held, petitioner incorrectly used the "official" rate of exchange (as opposed to the "commercial" rate of exchange) in converting the cost of Argentinian expenditures, incurred prior to petitioner's…

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1. Held, the good-faith filing of a Form 1065 partnership return reflecting petitioner's only source of income was not sufficient to start the running of the statute of limitations where petitioner had failed to file an individual return, as required by sec. 6012(a). 2. Held, petitioner incorrectly used the "official" rate of exchange (as opposed to the "commercial" rate of exchange) in converting the cost of Argentinian expenditures, incurred prior to petitioner's emigration to this country, into dollars. 3. Held, respondent's determination not arbitrary or unreasonable where respondent's…

1Opinion of the Court

Marko Durovic, Petitioner v. Commissioner of Internal Revenue, Respondent

Durovic v. Commissioner

Docket No. 1633-65

United States Tax Court

54 T.C. 1364; 1970 U.S. Tax Ct. LEXIS 105;

June 24, 1970, Filed

Decision will be entered under Rule 50.

1. Held, the good-faith filing of a Form 1065 partnership return reflecting petitioner's only source of income was not sufficient to start the running of the statute of limitations where petitioner had failed to file an individual return, as required by sec. 6012(a).

2. Held, petitioner incorrectly used the "official" rate of exchange (as opposed to the…

2Cases cited69 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
  3. Helvering v. TaylorSupreme Court of the United States · 1935
  4. Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
  5. Mitchell v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1941

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