SCOTT C. RETHORST, APPELLANT,
v.
COMMISSIONER OF INTERNAL REVENUE, APPELLEE; VEHICLE RESEARCH CORPORATION, APPELLANT, V. COMMISSIONER OF INTERNAL REVENUE, APPELLEE
SCOTT C. RETHORST, APPELLANT,
COMMISSIONER OF INTERNAL REVENUE, APPELLEE; VEHICLE RESEARCH CORPORATION, APPELLANT, V. COMMISSIONER OF INTERNAL REVENUE, APPELLEE
509 F.2d 623
United States Court of Appeals for the Ninth Circuit (1974)
Positive Treatment
Cited by 22 cases
Opinion of the Court
PER CURIAM:
The taxpayer appeals a decision of the Tax Court finding him liable for unpaid income taxes for the years 1961, 1962, 1963 and 1964. T.C. Memo. 1972-222, 31 CCH Tax.Ct.Mem. 1101 (1972). We affirm.
The facts are set out in detail in the Tax Court Memorandum. We have examined the lengthy record and are satisfied that there is substantial evidence to support the Tax Court’s finding that the taxpayer constructively received the income paid by the taxpayer’s wholly owned California corporation to a Swiss corporation controlled by the taxpayer. The record also supports the assessment of an addition to tax under Section 6653(a), Internal Revenue Code of 1954, for “negligence or intentional disregard of rules and regulations”.
Affirmed.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Cited By (11 total)
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Ferdinand D. Wharton, Jr. v. Knefel, 562 F.2d 550 (8th Cir. 1977)
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Bennett Robinson v. 12 Lofts Realty, Inc., 610 F.2d 1032 (2d Cir. 1979)
-
United States v. City OF Parma, 661 F.2d 562 (6th Cir. 1981)
Previewing 3 of 11 citing cases — full citator treatment, depth of discussion, and citing context are member features.
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