Roberts v. Commissioner
United States Tax Court
1. The petitioner refused to offer proof to establish his right to deductions for a casualty loss and employee business expenses. The Commissioner disallowed both deductions. Held, the Commissioner's determination not arbitrary or unreasonable where the petitioner refused to provide the Commissioner with any proof to support the deductions. Held, further, the petitioner has no right to have his return presumed correct.
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1. The petitioner refused to offer proof to establish his right to deductions for a casualty loss and employee business expenses. The Commissioner disallowed both deductions. Held, the Commissioner's determination not arbitrary or unreasonable where the petitioner refused to provide the Commissioner with any proof to support the deductions. Held, further, the petitioner has no right to have his return presumed correct. Held, further, the petitioner's privilege against self-incrimination not violated by requiring him to prove his deductions. Held, further, the petitioner did not meet his…
1Opinion of the Court
E. Jan Roberts, Petitioner v. Commissioner of Internal Revenue, Respondent
Roberts v. Commissioner
Docket No. 2868-72
United States Tax Court
62 T.C. 834; 1974 U.S. Tax Ct. LEXIS 42; 62 T.C. No. 89;
September 23, 1974, Filed
Decision will be entered for the respondent.
1. The petitioner refused to offer proof to establish his right to deductions for a casualty loss and employee business expenses. The Commissioner disallowed both deductions. Held, the Commissioner's determination not arbitrary or unreasonable where the petitioner refused to provide the Commissioner with any proof to support the…
2Cases cited50 opinions
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- Welch v. HelveringSupreme Court of the United States · 1933
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Sorrells v. United StatesSupreme Court of the United States · 1932
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