Legal Opinion

Cesanelli v. Commissioner

United States Tax Court

Decided April 3, 1947No. Docket Nos. 10002, 10003, 10004, 10005, 10006, 10007Published

1. Respondent's determination that petitioners, waiters in a restaurant, received income as tips in an amount equal to 10 per cent of sales to patrons, sustained. 2. Charge of fraud to evade taxes sustained.

1Opinion of the Court

Nazzareno D. Cesanelli, Petitioner, et al. 1 v. Commissioner of Internal Revenue, Respondent

Cesanelli v. Commissioner

Docket Nos. 10002, 10003, 10004, 10005, 10006, 10007

United States Tax Court

8 T.C. 776; 1947 U.S. Tax Ct. LEXIS 235;

April 3, 1947, Promulgated

Decisions will be entered under Rule 50.

1. Respondent's determination that petitioners, waiters in a restaurant, received income as tips in an amount equal to 10 per cent of sales to patrons, sustained.

2. Charge of fraud to evade taxes sustained.

Joseph A. Brown, Esq., for the petitioners.

Leonard A. Marcussen, Esq., for the respondent.

Van…

2Cases cited1 opinion

  1. Cesanelli v. CommissionerUnited States Tax Court · 1947

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