Legal Opinion

Casner v. Commissioner

United States Tax Court

Decided October 21, 1964No. Docket No. 4117-62Unpublished

Held: (1) Petitioner's books and records were inadequate to determine petitioner's taxable income for the taxable years in issue; (2) Respondent properly determined petitioner's income under the bank deposits and withdrawals method for the taxable years involved; (3) Part of the deficiencies in petitioner's income taxes for the taxable years in issue was due to fraud with intent to evade tax; (4) Imposition of the addition to tax for failure to file a declaration of…

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Held: (1) Petitioner's books and records were inadequate to determine petitioner's taxable income for the taxable years in issue; (2) Respondent properly determined petitioner's income under the bank deposits and withdrawals method for the taxable years involved; (3) Part of the deficiencies in petitioner's income taxes for the taxable years in issue was due to fraud with intent to evade tax; (4) Imposition of the addition to tax for failure to file a declaration of estimated tax for the years 1951 through 1954 is sustained.

1Opinion of the Court

Joseph Casner, Jr. v. Commissioner.

Casner v. Commissioner

Docket No. 4117-62.

United States Tax Court

T.C. Memo 1964-277; 1964 Tax Ct. Memo LEXIS 64; 23 T.C.M. (CCH) 1683; T.C.M. (RIA) 64277;

October 21, 1964

Held: (1) Petitioner's books and records were inadequate to determine petitioner's taxable income for the taxable years in issue;(2) Respondent properly determined petitioner's income under the bank deposits and withdrawals method for the taxable years involved;(3) Part of the deficiencies in petitioner's income taxes for the taxable years in issue was due to fraud with intent to evade…

2Cases cited7 opinions

  1. Halle v. CommissionerUnited States Tax Court · 1946
  2. Halle v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1949
  3. Vassallo v. CommissionerUnited States Tax Court · 1955
  4. Harbin v. CommissionerUnited States Tax Court · 1963
  5. Marinzulich v. CommissionerUnited States Tax Court · 1958

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