Wasman v. Comm'r
United States Tax Court
Held: (1) Respondent's reconstruction of petitioner's income sustained. (2) Sale of stock by petitioner allegedly acting as trustee resulted in income to petitioner on the ground that petitioner could not substantiate that he was acting in a fiduciary capacity. (3) Underpayments for the years 1967-1970 were due to fraud and accordingly respondent's imposition of the fraud penalty under sec. 6653(b) for each of the years is sustained.
1Opinion of the Court
MILTON WASMAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Wasman v. Comm'r
Docket No. 5515-77.
United States Tax Court
T.C. Memo 1982-281; 1982 Tax Ct. Memo LEXIS 465; 43 T.C.M. (CCH) 1434; T.C.M. (RIA) 82281;
May 20, 1982.
Held: (1) Respondent's reconstruction of petitioner's income sustained.(2) Sale of stock by petitioner allegedly acting as trustee resulted in income to petitioner on the ground that petitioner could not substantiate that he was acting in a fiduciary capacity.(3) Underpayments for the years 1967-1970 were due to fraud and accordingly respondent's imposition of…
2Cases cited20 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
- James v. United StatesSupreme Court of the United States · 1961
- Stone v. CommissionerUnited States Tax Court · 1971
- Otsuki v. CommissionerUnited States Tax Court · 1969
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