FOUTZ v. COMMISSIONER
United States Tax Court
Respondent used the bank deposits method of recomputing income, due to inadequate records maintained by petitioners. Petitioners refused to supply possible corroborating information due to their fear of possible criminal prosecution.Held, undisputed increase in petitioners' bank accounts, all designated as being generated from business activities, are sufficient to carry respondent's burden of showing omissions from gross income for purposes of section 6501(e)(1) (A)(i),…
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Respondent used the bank deposits method of recomputing income, due to inadequate records maintained by petitioners. Petitioners refused to supply possible corroborating information due to their fear of possible criminal prosecution.Held, undisputed increase in petitioners' bank accounts, all designated as being generated from business activities, are sufficient to carry respondent's burden of showing omissions from gross income for purposes of section 6501(e)(1) (A)(i), thus shifting to petitioners the burden of explaining why the increases do not represent taxable income. Petitioners' fear…
1Opinion of the Court
HAL B. FOUTZ AND LIANE FOUTZ, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
FOUTZ v. COMMISSIONER
Docket Nos. 3396-73, 2625-74.
United States Tax Court
T.C. Memo 1978-471; 1978 Tax Ct. Memo LEXIS 44; 37 T.C.M. (CCH) 1849-12;
November 27, 1978, Filed
Respondent used the bank deposits method of recomputing income, due to inadequate records maintained by petitioners. Petitioners refused to supply possible corroborating information due to their fear of possible criminal prosecution.Held, undisputed increase in petitioners' bank accounts, all designated as being generated from business…
2Cases cited1 opinion
- Estate of Kopperman v. CommissionerUnited States Tax Court · 1978