T.C. Memo. 1999-189
UNITED STATES TAX COURT
BEATRICE DIPIERRO, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 12950-97. Filed June 9, 1999.
R determined deficiencies in P’s income tax
liability on account of petitioner’s failure to account
for certain cash transactions.
Held: P has failed to prove nontaxable sources
for the cash transactions, which is prima facie
evidence of income. See Tokarski v. Commissioner,
87 T.C. 74 (1986).
Held, further, P is liable for tax on self-
employment income.
Held, further, P is liable for sec. 6662(a),
I.R.C., accuracy-related penalty.
B. Gray Gibbs, for petitioner.
Judith C. Winkler and Howard P. Levine, for respondent.
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