Hecht v. Commissioner
United States Tax Court
1. Section 3801. -- Adjustment on Account of Taxes Paid by Others -- Related Taxpayer. -- The taxpayers are not entitled to adjustments under section 3801 to their own tax liabilities for reimbursements made to dummies on account of taxes paid by dummies who, under a scheme of deception, reported and paid taxes on income realized by the taxpayers since the dummies were not "related taxpayers" within the meaning of the section and since the section was never intended to apply…
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1. Section 3801. -- Adjustment on Account of Taxes Paid by Others -- Related Taxpayer. -- The taxpayers are not entitled to adjustments under section 3801 to their own tax liabilities for reimbursements made to dummies on account of taxes paid by dummies who, under a scheme of deception, reported and paid taxes on income realized by the taxpayers since the dummies were not "related taxpayers" within the meaning of the section and since the section was never intended to apply to any such fraudulent scheme in any event. 2. Fraud -- Addition under Section 293 (b). -- A part of each deficiency…
1Opinion of the Court
OPINION.
Mukdock, Judge:
It is conceded that six of the unexplained bank deposits in the accounts of Susan represented unreported interest and, therefore; the Commissioner was right in adding those to income. Susan testified in regard to the other questioned deposits and hep testimony satisfies the Court that they did not represent income. Hecht was questioned about his unexplained deposits and in a few instances gave explanations which, if he can be believed, would indicate that the deposits did not represent income to him. However, his testimony in regard to many of the deposits was vague and…
2Cases cited2 opinions
- Spies v. United StatesSupreme Court of the United States · 1943
- National City Bank of New York v. HelveringCourt of Appeals for the Second Circuit · 1938
3Cited by15 opinions
- Joseph P. McGraw v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 2004
- Olaf E. Taxeraas, Administrator of the Estate of Carl Taxeraas and Irene Taxeraas v. United StatesCourt of Appeals for the Eighth Circuit · 1959
- Hall v. CommissionerUnited States Tax Court · 1976
- BIAGGI v. COMMISSIONERUnited States Tax Court · 2000
- Taxeraas v. United StatesDistrict Court, D. Minnesota · 1958
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