- 8 - 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).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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