Cox v. Commissioner
United States Tax Court
1. The petitioner has, since 1951, been engaged in farming. He failed to file income tax returns for the taxable years 1951 through 1963. In the absence of adequate records, the respondent computed the petitioner's taxable income on the net worth plus nondeductible expenditures method.
Read the full summary
1. The petitioner has, since 1951, been engaged in farming. He failed to file income tax returns for the taxable years 1951 through 1963. In the absence of adequate records, the respondent computed the petitioner's taxable income on the net worth plus nondeductible expenditures method. The petitioner had no net worth at Jan. 1, 1951, and it was possible to compute his net worth as of Dec. 31, 1963. However, the petitioner's net worth as of the end of any of the intervening years could not be determined. Accordingly, the respondent computed the petitioner's increase in net worth over the…
1Opinion of the Court
OPINION
In the petition, petitioner asserts that assessment and collection of the deficiencies and additions to tax for 10 of the years involved are barred by the statute of limitations. Section 276(a) of the Internal Revenue Code of 1939 1 and section 6501(c) (3) of the Internal Revenue Code of 19542 both provide that the tax may be assessed, or a proceeding in court for the collection thereof may be begun without assessment, at any time where there has been a failure to file a return. For the taxable years 1951 through 1963, petitioner failed to file any tax returns. Clearly, assessment and…
2Cases cited6 opinions
- Rodney v. Comm'rUnited States Tax Court · 1969
- Heman v. CommissionerUnited States Tax Court · 1959
- Hurley v. CommissionerUnited States Tax Court · 1954
- Bartlett v. CommissionerUnited States Tax Court · 1954
- H. A. Hurley and H. A. And Opal Hurley v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1956
1 more not listed; retrieve them via the Exa API.
3Cited by4 opinions
- Zaun v. CommissionerUnited States Tax Court · 1974
- Cox v. CommissionerUnited States Tax Court · 1970
- Fisher v. CommissionerUnited States Tax Court · 1988
- Zaun v. CommissionerUnited States Tax Court · 1974