Houser v. Commissioner
United States Tax Court
P is a physician. P's accountant (W) calculated P's medical practice receipts with the understanding that W was to use the subtraction method, as follows: P was to deposit receipts from all sources into an account in A Bank; W then subtracted receipts known to be from other activities and the remainder would be medical practice receipts. P did not deposit all his receipts into the A Bank account.
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P is a physician. P's accountant (W) calculated P's medical practice receipts with the understanding that W was to use the subtraction method, as follows: P was to deposit receipts from all sources into an account in A Bank; W then subtracted receipts known to be from other activities and the remainder would be medical practice receipts. P did not deposit all his receipts into the A Bank account. P concedes that, as a result, P's medical practice receipts were substantially understated. The notice of deficiency for 1977 through 1984 was sent to P more than 3 years after he filed his tax…
1Opinion of the Court
WILLIAM H. HOUSER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Houser v. Commissioner
Docket No. 18937-88
United States Tax Court
T.C. Memo 1995-330; 1995 Tax Ct. Memo LEXIS 326; 70 T.C.M. (CCH) 131;
July 24, 1995, Filed
Decision will be entered under Rule 155.
P is a physician. P's accountant (W) calculated P's medical practice receipts with the understanding that W was to use the subtraction method, as follows: P was to deposit receipts from all sources into an account in A Bank; W then subtracted receipts known to be from other activities and the remainder would be medical practice…
2Cases cited51 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Stone v. CommissionerUnited States Tax Court · 1971
- Wichita Term. El. Co. v. Commissioner of Int. R.Court of Appeals for the Tenth Circuit · 1947
- Gajewski v. CommissionerUnited States Tax Court · 1976
- Otsuki v. CommissionerUnited States Tax Court · 1969
46 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- In re WylyUnited States Bankruptcy Court, N.D. Texas · 2016