Sacco v. Commissioner
United States Tax Court
Respondent determined deficiencies for 1977, 1979, and 1980, based on unreported income from a photography business. Held: (1) Respondent has not met his burden of proving a substantial omission of income for 1977; the statute of limitations bars assessment and collection for that year. Secs. 6501(e)(1)(A) and 6501(a), I.R.C. 1954. (2) Petitioners have not met their burden of proof as to the unreported income; deductions allowed. Cohen v. Commissioner,39 F.2d 540 (CA2 1930).
1Opinion of the Court
RICHARD S. SACCO AND JACQUELINE SACCO, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Sacco v. Commissioner
Docket No. 13884-83
United States Tax Court
T.C. Memo 1988-532; 1988 Tax Ct. Memo LEXIS 562; 56 T.C.M. (CCH) 684; T.C.M. (RIA) 88532;
November 16, 1988; As amended November 22, 1988
Respondent determined deficiencies for 1977, 1979, and 1980, based on unreported income from a photography business.
Held: (1) Respondent has not met his burden of proving a substantial omission of income for 1977; the statute of limitations bars assessment and collection for that year. Secs.…
2Cases cited20 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Helvering v. TaylorSupreme Court of the United States · 1935
- Meneguzzo v. CommissionerUnited States Tax Court · 1965
- Giddio v. CommissionerUnited States Tax Court · 1970
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