Legal Opinion

Adams v. Comm'r

United States Tax Court

Decided April 19, 1978No. Docket Nos. 7034-72 and 7042-72Unpublished

Petitioner grossly understated his income in the years 1963 through 1968. Records maintained by petitioner were inadequate and respondent was required to reconstruct his income. Petitioner also managed his business affairs in such a manner as to conceal his true income. He sold nine pieces of property during the years in issue which were held from between one and seven years.

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Petitioner grossly understated his income in the years 1963 through 1968. Records maintained by petitioner were inadequate and respondent was required to reconstruct his income. Petitioner also managed his business affairs in such a manner as to conceal his true income. He sold nine pieces of property during the years in issue which were held from between one and seven years. He did not have a real estate license, and earnings from real estate dealings were comparatively low to his gross income from other sources. Held, petitioner's returns for 1963 through 1968 were false and fraudulent with…

1Opinion of the Court

J. NORWOOD ADAMS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

J. NORWOOD ADAMS and VALERIA ADAMS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Adams v. Comm'r

Docket Nos. 7034-72 and 7042-72.

United States Tax Court

T.C. Memo 1978-152; 1978 Tax Ct. Memo LEXIS 363; 37 T.C.M. (CCH) 654; T.C.M. (RIA) 780152;

April 19, 1978, Filed

Petitioner grossly understated his income in the years 1963 through 1968. Records maintained by petitioner were inadequate and respondent was required to reconstruct his income. Petitioner also managed his business affairs in such a manner as to…

2Cases cited16 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Holland v. United StatesSupreme Court of the United States · 1955
  3. Spies v. United StatesSupreme Court of the United States · 1943
  4. Stone v. CommissionerUnited States Tax Court · 1971
  5. Greenberg's Express, Inc. v. CommissionerUnited States Tax Court · 1974

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