Legal Opinion

Stratton v. Commissioner

United States Tax Court

Decided February 12, 1970No. Docket No. 4166-65PublishedCited by 163 opinions

Petitioner was Governor of the State of Illinois for the 8 years here in question. He personally prepared and filed joint Federal income tax returns for 1953 through 1960, reporting a net income for the 8 years of $ 171,846.93. Respondent, using the net worth plus nondeductible expenditures method, determined petitioners' net income for the 8 years to be $ 369,096.29, which he reduced in his brief to $ 366,184.92. He also determined that at least a part of the deficiencies…

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Petitioner was Governor of the State of Illinois for the 8 years here in question. He personally prepared and filed joint Federal income tax returns for 1953 through 1960, reporting a net income for the 8 years of $ 171,846.93. Respondent, using the net worth plus nondeductible expenditures method, determined petitioners' net income for the 8 years to be $ 369,096.29, which he reduced in his brief to $ 366,184.92. He also determined that at least a part of the deficiencies were due to fraud with intent to evade tax. Prior to this determination, petitioner was indicted, tried, and acquitted…

1Opinion of the Court

OPINION

The three issues previously stated are primarily questions of fact which have been resolved in our ultimate findings.

Respondent’s case is premised on a net worth plus nondeductible expenditures approach covering the calendar years 1953 through 1960 while petitioner William G. Stratton was Governor of the State of Illinois. The respondent’s computations under this approach which were part of the statement attached to the deficiency notice are set out in our findings. Petitioners challenge the appropriateness of respondent’s use of the net worth method on the ground that they maintained…

2Cases cited40 opinions

  1. Holland v. United StatesSupreme Court of the United States · 1955
  2. Commissioner v. DubersteinSupreme Court of the United States · 1960
  3. Spies v. United StatesSupreme Court of the United States · 1943
  4. Helvering v. MitchellSupreme Court of the United States · 1938
  5. Otsuki v. CommissionerUnited States Tax Court · 1969

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

3Cited by163 opinions

  1. Grosshandler v. CommissionerUnited States Tax Court · 1980
  2. Hebrank v. CommissionerUnited States Tax Court · 1983
  3. Doncaster v. CommissionerUnited States Tax Court · 1981
  4. Minahan v. CommissionerUnited States Tax Court · 1987
  5. Professional Services v. CommissionerUnited States Tax Court · 1982

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

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