Greenway v. Commissioner
United States Tax Court
Respondent determined numerous specific adjustments to petitioners' income for the years 1970 through 1976. Additionally, respondent determined unreported income based on the source and application of funds method of income reconstruction.
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Respondent determined numerous specific adjustments to petitioners' income for the years 1970 through 1976. Additionally, respondent determined unreported income based on the source and application of funds method of income reconstruction. Held: the statute of limitations bars the assessment and collection of deficiencies in income tax and additions to tax for the years 1970 and 1973. Held further, respondent's specific adjustments for the years 1971, 1972, and 1974 through 1976 are sustained; held further, respondent's source and application of funds determinations are sustained for the…
1Opinion of the Court
JERRY G. GREENWAY AND BETTY R. GREENWAY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Greenway v. Commissioner
Docket No. 17986-82.
United States Tax Court
T.C. Memo 1987-4; 1987 Tax Ct. Memo LEXIS 4; 52 T.C.M. (CCH) 1283; T.C.M. (RIA) 87004;
January 5, 1987.
Respondent determined numerous specific adjustments to petitioners' income for the years 1970 through 1976. Additionally, respondent determined unreported income based on the source and application of funds method of income reconstruction. Held: the statute of limitations bars the assessment and collection of deficiencies in…
2Cases cited24 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Holland v. United StatesSupreme Court of the United States · 1955
- Stone v. CommissionerUnited States Tax Court · 1971
- Gajewski v. CommissionerUnited States Tax Court · 1976
- Beaver v. CommissionerUnited States Tax Court · 1970
19 more not listed; retrieve them via the Exa API.
3Cited by2 opinions
- Benson v. Comm'rUnited States Tax Court · 2006
- Smith v. CommissionerUnited States Tax Court · 1991