Legal Opinion

Conti v. Commissioner

United States Tax Court

Decided October 19, 1992No. Docket No. 15131-90Unpublished

R determined deficiencies in income tax and additions to tax for 1986 and 1987 using the net worth plus expenditures method. Ps claim that the increase in net worth determined by respondent was due to withdrawals from an $ 800,000 cash hoard and $ 550,000 in loans from their son. Held: R's determination of deficiencies as amended is sustained. Held further: Additions to tax under secs. 6653(b) and 6661 as amended are sustained.

1Opinion of the Court

GUILIO J. AND EDITH CONTI, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Conti v. Commissioner

Docket No. 15131-90

United States Tax Court

T.C. Memo 1992-616; 1992 Tax Ct. Memo LEXIS 645; 64 T.C.M. (CCH) 1093;

October 19, 1992, Filed

Decision will be entered under Rule 155.

R determined deficiencies in income tax and additions to tax for 1986 and 1987 using the net worth plus expenditures method. Ps claim that the increase in net worth determined by respondent was due to withdrawals from an $ 800,000 cash hoard and $ 550,000 in loans from their son.

Held: R's determination of…

2Cases cited56 opinions

  1. Holland v. United StatesSupreme Court of the United States · 1955
  2. Spies v. United StatesSupreme Court of the United States · 1943
  3. Rowlee v. CommissionerUnited States Tax Court · 1983
  4. Stone v. CommissionerUnited States Tax Court · 1971
  5. Gajewski v. CommissionerUnited States Tax Court · 1976

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