Legal Opinion
Ernest N. Delaney and Marjorie M. Delaney v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided September 21, 1984No. 83-7627PublishedCited by 40 opinions
1Opinion of the Court
KENNEDY, Circuit Judge:
The Tax Court affirmed the IRS’s determination that $43,000 in Swiss gold coins and $305 in unexplained bank deposits constituted unreported income. The Delaneys now appeal, challenging the assessment of a deficiency and a negligence penalty pursuant to 26 U.S.C. § 6653(a). We affirm.
The Commissioner’s deficiency determination is entitled to a presumption of correctness “once some substantive evidence is introduced demonstrating that the taxpayer received unreported income.” Edwards v. Commissioner, 680 F.2d 1268, 1270 (9th Cir.1982) (per curiam), quoted in United…
2Cases cited8 opinions
- Johnny Weimerskirch v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1979
- William H. And Avilda L. Edwards v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1982
- William R. And Lorna E. Hall v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1984
- United States v. StonehillCourt of Appeals for the Ninth Circuit · 1983
- Mary Ruark v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1971
3 more not listed; retrieve them via the Exa API.
3Cited by40 opinions
- Robert W. Bradford v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1986
- Petzoldt v. CommissionerUnited States Tax Court · 1989
- Cathy Miller Hardy v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1999
- Gerald J. Rapp and Mary H. Rapp v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1985
- William E. Neely and Irene R. Neely v. United StatesCourt of Appeals for the Ninth Circuit · 1985
35 more not listed; retrieve them via the Exa API.