- 15 - v. United States, supra at 125, 137; Estate of Mazzoni v. Commissioner, 451 F.2d 197, 199 (3d Cir. 1971), affg. Mazzoni v. Commissioner, T.C. Memo. 1970-37, supplemented by Estate of Mazzoni v. Commissioner, T.C. Memo. 1970-144. To use the net worth method, the Commissioner must meet three requirements: first, the Commissioner must reliably establish a net worth for taxpayer as of the beginning of the period under review; second, investigation is required of the taxpayer's explanation for his net worth increases, if such "leads" are "reasonably susceptible of being checked;" finally, the government must suggest a "likely source" of the unreported income. Estate of Mazzoni v. Commissioner, supra at 200 (citation and fn. ref. omitted). Petitioners do not dispute that this is the applicable legal standard. 3. Whether Respondent Had a Basis in Law for Determining That Petitioners Are Liable for the Addition to Tax for Fraud Respondent's basis in law for determining that petitioners were liable for the addition to tax for fraud is section 6653(b) and the many cases which apply it. The parties do not dispute what legal standards apply under section 6653(b). We conclude that respondent had a basis in law to determine that petitioners were liable for the addition to tax for fraud.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011