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crime other than that specified in the order of
authorization or approval. Accordingly, the Court of
Appeals approved the District Court's dismissal of the
indictment as a sanction for the Government's failure to
obtain the order required by 18 U.S.C. section 2517(5).
Net Worth Computation
Taxpayers are required to keep adequate books or
records from which their correct tax liability can be
determined. Sec. 6001. In the absence of such books or
records, the Commissioner is entitled to reconstruct a
taxpayer's income by any reasonable means. Sec. 446(b).
The net worth method is an indirect method of reconstruct-
ing taxable income that has long been approved by the
courts. See, e.g., Holland v. United States, 348 U.S. 121,
131 (1954); Manzoli v. Commissioner, 904 F.2d 101 (1st Cir.
1990), affg. T.C. Memo. 1989-94 and T.C. Memo. 1988-299;
United States v. Sorrentino, 726 F.2d 876 (1st Cir. 1984);
Mazzoni v. Commissioner, 451 F.2d 197 (3d Cir. 1971),
affg. T.C. Memo. 1970-144 and T.C. Memo. 1970-37; McGarry
v. United States, 388 F.2d 862 (1st Cir. 1967).
Under the net worth method, the Commissioner seeks to
compute taxable income in a given year by determining from
all available evidence of assets and liabilities the
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