Legal Opinion

Lovallo v. Commissioner

United States Tax Court

Decided July 25, 1950No. Docket Nos. 19184, 19653, 19654Unpublished

During the taxable years 1944, 1945 and 1946, petitioner owned and operated a bar and restaurant. He filed returns for these years purporting to show the net income from this business. Respondent determined that these returns did not correctly reflect income on the grounds that petitioner's purchases were overstated.

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During the taxable years 1944, 1945 and 1946, petitioner owned and operated a bar and restaurant. He filed returns for these years purporting to show the net income from this business. Respondent determined that these returns did not correctly reflect income on the grounds that petitioner's purchases were overstated. Respondent also eliminated petitioner's opening inventory in his return for the year 1946, that being the first year that petitioner used inventories in his business. In an amended answer respondent also alleges affirmatively that petitioner understated his sales for each of the…

1Opinion of the Court

Michael Lovallo v. Commissioner.

Lovallo v. Commissioner

Docket Nos. 19184, 19653, 19654.

United States Tax Court

1950 Tax Ct. Memo LEXIS 138; 9 T.C.M. (CCH) 634; T.C.M. (RIA) 50184;

July 25, 1950

During the taxable years 1944, 1945 and 1946, petitioner owned and operated a bar and restaurant. He filed returns for these years purporting to show the net income from this business. Respondent determined that these returns did not correctly reflect income on the grounds that petitioner's purchases were overstated. Respondent also eliminated petitioner's opening inventory in his return for the year…

2Cases cited1 opinion

  1. Barbas v. CommissionerUnited States Board of Tax Appeals · 1925

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