Armin Unger - Page 8




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          mother, or in her own name.  However, the evidence shows that                
          petitioner transferred significant amounts of money to his                   
          mother’s accounts and had access to and control over those bank              
          accounts.  During the years in issue, Helen Unger was retired and            
          had a modest income.  Her gross income, which conceivably could              
          have been a source of some funds deposited to those accounts, was            
          subtracted from respondent’s net worth computation in arriving at            
          petitioner’s understatement of income.                                       
               When ownership or the source from which assets are purchased            
          by a taxpayer and his family are confused, the Commissioner is               
          permitted to resort to the use of a consolidated net worth                   
          statement.  See Smith v. Commissioner, 31 T.C. 1 (1958); Lias v.             
          Commissioner, 24 T.C. 280 (1955), affd. 235 F.2d 879 (4th Cir.               
          1956).  Under the consolidated method, the combined taxable                  
          income of the taxpayer and his family group is determined by                 
          taking the increase in their combined net worth during each year,            
          adding personal expenses paid each year, and making proper                   
          adjustments.  From the combined taxable net income determined                
          under this method, the income reported for the other members of              
          the family group is deducted, leaving the taxable net income of              
          the taxpayer.  See Lias v. Commissioner, supra; Friedman v.                  
          Commissioner, T.C. Memo. 1968-145, affd. 421 F.2d 658 (6th Cir.              
          1970).                                                                       








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