DAVIES v. COMMISSIONER
United States Tax Court
The male petitioners worked as blackjack (21), big wheel (Big 6), and roulette dealers at a Las Vegas, Nevada, casino-hotel. Respondent determined deficiencies based on "toke" income in addition to the amounts petitioners reported. Held: (1) Equitable estoppel and laches do not bar respondent's deficiency determinations. (2) Respondent's determinations were not arbitrary and excessive and so are presumptively correct. (3) Tokes constitute taxable income.
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The male petitioners worked as blackjack (21), big wheel (Big 6), and roulette dealers at a Las Vegas, Nevada, casino-hotel. Respondent determined deficiencies based on "toke" income in addition to the amounts petitioners reported. Held: (1) Equitable estoppel and laches do not bar respondent's deficiency determinations. (2) Respondent's determinations were not arbitrary and excessive and so are presumptively correct. (3) Tokes constitute taxable income. (4) Amounts of toke income are determined. (5) Statute of limitations does not bar deficiencies for 1969 and 1970 in docket No. 7945-78.…
1Opinion of the Court
NORMAN R. DAVIES AND JUDITH A. DAVIES, ET AL., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
DAVIES v. COMMISSIONER
Docket Nos. 5080-77, 7815-78, 7816-78, 7817-78, 7818-78, 7945-78.
United States Tax Court
T.C. Memo 1981-438; 1981 Tax Ct. Memo LEXIS 309; 42 T.C.M. (CCH) 768; T.C.M. (RIA) 81438;
August 17, 1981.
The male petitioners worked as blackjack (21), big wheel (Big 6), and roulette dealers at a Las Vegas, Nevada, casino-hotel. Respondent determined deficiencies based on "toke" income in addition to the amounts petitioners reported.
Held: (1) Equitable estoppel and laches do…
2Cases cited34 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Helvering v. TaylorSupreme Court of the United States · 1935
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
- Dixon v. United StatesSupreme Court of the United States · 1965
- Johnny Weimerskirch v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1979
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3Cited by2 opinions
- Davies v. CommissionerCourt of Appeals for the Ninth Circuit · 1983
- Davies v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1983