Legal Opinion

Gerber & Associates, Inc. v. Commissioner

United States Tax Court

Decided September 2, 1987No. Docket Nos. 18564-81; 18565-81; 22482-81UnpublishedCited by 3 opinions

Held: (1) For 1973 through 1976, Ps understated their taxable income and underpaid their taxes in the amounts determined by the Commissioner by means of the source and application of funds method of reconstruction of income; (2) For 1977, Ps are not entitled to claim a short-term capital loss with respect to certain shares of stock; (3) For 1977 and 1978, the Commissioner's determinations concerning deductions and a credit claimed for certain alleged business expenses are…

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Held: (1) For 1973 through 1976, Ps understated their taxable income and underpaid their taxes in the amounts determined by the Commissioner by means of the source and application of funds method of reconstruction of income; (2) For 1977, Ps are not entitled to claim a short-term capital loss with respect to certain shares of stock; (3) For 1977 and 1978, the Commissioner's determinations concerning deductions and a credit claimed for certain alleged business expenses are upheld; (4) For 1977, Ps, as partners, must include in income their share of funds received by the partnership but not…

1Opinion of the Court

GERBER AND ASSOCIATES, INC., ET AL., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Gerber & Associates, Inc. v. Commissioner

Docket Nos. 18564-81; 18565-81; 22482-81.

United States Tax Court

T.C. Memo 1987-446; 1987 Tax Ct. Memo LEXIS 443; 54 T.C.M. (CCH) 420; T.C.M. (RIA) 87446;

September 2, 1987.

Held: (1) For 1973 through 1976, Ps understated their taxable income and underpaid their taxes in the amounts determined by the Commissioner by means of the source and application of funds method of reconstruction of income;(2) For 1977, Ps are not entitled to claim a short-term capital…

2Cases cited35 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Holland v. United StatesSupreme Court of the United States · 1955
  3. New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
  4. Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
  5. Commissioner v. HeiningerSupreme Court of the United States · 1943

30 more not listed; retrieve them via the Exa API.

3Cited by3 opinions

  1. BERRY v. COMMISSIONERUnited States Tax Court · 2001
  2. Carraway v. CommissionerUnited States Tax Court · 1994
  3. Hobson Motor Co. v. CommissionerUnited States Tax Court · 1990

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