Sly v. Comm'r
United States Tax Court
Held: Petitioners have not shown that respondent's reconstruction of their income for 1977 and 1978 and the determination of an addition to tax for negligence under section 6653(a) for those years are incorrect. Held further: as petitioners have not substantiated some expenditures for 1980, 1981, and 1982 as required by section 274(d), those expenditures will be disallowed as deductions.
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Held: Petitioners have not shown that respondent's reconstruction of their income for 1977 and 1978 and the determination of an addition to tax for negligence under section 6653(a) for those years are incorrect. Held further: as petitioners have not substantiated some expenditures for 1980, 1981, and 1982 as required by section 274(d), those expenditures will be disallowed as deductions. Held further: petitioners have proven that respondent erred in attributing to them the income of certain corporations in which petitioners had an interest. Held further: respondent's motion for default…
1Opinion of the Court
DONA H. SLY AND JOANN E. SLY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Sly v. Comm'r
Docket Nos. 23814-82; 538-85; 42908-85.
United States Tax Court
T.C. Memo 1988-443; 1988 Tax Ct. Memo LEXIS 482; 56 T.C.M. (CCH) 209; T.C.M. (RIA) 88443;
September 15, 1988.
Held: Petitioners have not shown that respondent's reconstruction of their income for 1977 and 1978 and the determination of an addition to tax for negligence under section 6653(a) for those years are incorrect. Held further: as petitioners have not substantiated some expenditures for 1980, 1981, and 1982 as required by…
2Cases cited30 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Holland v. United StatesSupreme Court of the United States · 1955
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Spies v. United StatesSupreme Court of the United States · 1943
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
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3Cited by2 opinions
- Sly v. United States (In Re Sly)United States Bankruptcy Court, N.D. Florida · 2003
- Sly v. United StatesUnited States Bankruptcy Court, N.D. Florida · 2004