Thomas v. Commissioner
United States Tax Court
Ps, husband and wife, were engaged in the trucking business during the years 1970 through 1974. They did not file returns for such years until Nov. 12, 1981, over 3 years after they commenced this case. They did not provide their books and records to the Commissioner during the audit. The Commissioner determined deficiencies in Ps' income taxes for each of the years in issue by using the net worth method.
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Ps, husband and wife, were engaged in the trucking business during the years 1970 through 1974. They did not file returns for such years until Nov. 12, 1981, over 3 years after they commenced this case. They did not provide their books and records to the Commissioner during the audit. The Commissioner determined deficiencies in Ps' income taxes for each of the years in issue by using the net worth method. Held: (1) The Commissioner's net worth determinations, as modified by his concessions and by this opinion, are sustained. (2) Ps are not liable for the addition to tax for fraud for any of…
1Opinion of the Court
HARVEY and AUDREY THOMAS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Thomas v. Commissioner
Docket No. 12904-78.
United States Tax Court
T.C. Memo 1984-72; 1984 Tax Ct. Memo LEXIS 605; 47 T.C.M. (CCH) 1091; T.C.M. (RIA) 84072;
February 13, 1984.
Ps, husband and wife, were engaged in the trucking business during the years 1970 through 1974. They did not file returns for such years until Nov. 12, 1981, over 3 years after they commenced this case. They did not provide their books and records to the Commissioner during the audit. The Commissioner determined deficiencies in Ps' income…
2Cases cited33 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Holland v. United StatesSupreme Court of the United States · 1955
- Helvering v. TaylorSupreme Court of the United States · 1935
- Gajewski v. CommissionerUnited States Tax Court · 1976
- Beaver v. CommissionerUnited States Tax Court · 1970
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