109 T.C. No. 11
UNITED STATES TAX COURT
JOHN M. AND RITA K. MONAHAN, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 11062-95. Filed October 23, 1997.
1. Held: This Court may raise sua sponte the
doctrine of issue preclusion, or collateral estoppel.
2. Held, further, interest payments that were
credited to a partnership's bank account are taxable to
Ps because P controlled partnership matters and
benefited from and controlled the funds in that
account.
3. Held, further, a $25,000 payment that was
deposited in Ps' bank account is taxable to Ps because
Ps failed to prove that the payment represents
reimbursement of legal fees paid by P on behalf of a
corporation.
4. Held, further, sec. 6662(a), I.R.C., accuracy-
related penalty imposed for substantial understatement
of income tax.
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