Wilson v. Commissioner
United States Board of Tax Appeals
1. Revenue agents' reports not shown to have been used by the Commissioner of Internal Revenue in the determination of deficiencies are not proof of the adjustments made by the Commissioner even though in some instances the deficiencies proposed in such reports are identical with the deficiencies found by the Commissioner. 2. The Commissioner, in computing the distributive shares of partners in the net income of a partnership, need not, as a general principle, take into…
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1. Revenue agents' reports not shown to have been used by the Commissioner of Internal Revenue in the determination of deficiencies are not proof of the adjustments made by the Commissioner even though in some instances the deficiencies proposed in such reports are identical with the deficiencies found by the Commissioner. 2. The Commissioner, in computing the distributive shares of partners in the net income of a partnership, need not, as a general principle, take into consideration and make adjustments for the fact that an asset of the partnership sold during the year might, as to the…
1Opinion of the Court
*1284OPINION.
Murdock:
The Commissioner’s deficiency notices upon which the present proceedings are based do not disclose the method by which the Commissioner arrived at each deficiency, but, except in the case of Mrs. Henry Wilson, state that the explanation of the adjustments made in the determination of the taxpayer’s income-tax liabilities is set forth in certain office letters. In no instance have the petitioners put in evidence the office letters referred to in the deficiency notices. They did, however, offer in evidence revenue agents’ reports in which certain proposed deficiencies for the…
2Cited by23 opinions
- Shelton v. CommissionerUnited States Tax Court · 1974
- Clifford O. Boren v. R. A. Riddell, District Director of Internal RevenueCourt of Appeals for the Ninth Circuit · 1957
- Heaberlin v. CommissionerUnited States Tax Court · 1960
- Ruidoso Racing Asso. v. CommissionerUnited States Tax Court · 1971
- Heinemann Chemical Co. v. HeinerCourt of Appeals for the Third Circuit · 1937
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