Estate of Spear v. Commissioner
United States Tax Court
R determined deficiencies and additions to tax for 1975, 1976, and 1977 using the net worth plus expenditures method. Ps claim that the increase in net worth determined by R was due to expenditures from a $ 380,000 cash hoard and loan repayments. Petitioner Jeanette Spear failed to comply with a Court order to appear at trial. At trial, the Court concluded that her refusal to appear was a manipulation to avoid her testimonial responsibilities.
Read the full summary
R determined deficiencies and additions to tax for 1975, 1976, and 1977 using the net worth plus expenditures method. Ps claim that the increase in net worth determined by R was due to expenditures from a $ 380,000 cash hoard and loan repayments. Petitioner Jeanette Spear failed to comply with a Court order to appear at trial. At trial, the Court concluded that her refusal to appear was a manipulation to avoid her testimonial responsibilities. The Court sanctioned Ps by ordering that R is deemed to have made a prima facie showing of facts stated in the amended answer relating to R's fraud…
1Opinion of the Court
ESTATE OF LEON SPEAR, DECEASED, JEANETTE SPEAR, HARVEY SPEAR, AND ROBERT SPEAR, ADMINISTRATORS, AND JEANETTE SPEAR, ET AL., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Estate of Spear v. Commissioner
Docket Nos. 3276-87, 21480-90, 21481-90
United States Tax Court
T.C. Memo 1993-213; 1993 Tax Ct. Memo LEXIS 208; 65 T.C.M. (CCH) 2668; T.C.M. (RIA) 93213;
May 18, 1993, Filed; As Amended May 25, 1993
R determined deficiencies and additions to tax for 1975, 1976, and 1977 using the net worth plus expenditures method. Ps claim that the increase in net worth determined by R was due to…
2Cases cited63 opinions
- Link v. Wabash RailroadSupreme Court of the United States · 1962
- Holland v. United StatesSupreme Court of the United States · 1955
- Spies v. United StatesSupreme Court of the United States · 1943
- Rowlee v. CommissionerUnited States Tax Court · 1983
- Stone v. CommissionerUnited States Tax Court · 1971
58 more not listed; retrieve them via the Exa API.
3Cited by2 opinions
- Estate of Spear v. CommissionerUnited States Tax Court · 1997
- Franchi v. CommissionerUnited States Tax Court · 1995