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Full-Text Articles in Taxation-Federal
The Likely Source: An Unexplored Weakness In The Net Worth Method Of Proof, Ian M. Comisky
The Likely Source: An Unexplored Weakness In The Net Worth Method Of Proof, Ian M. Comisky
University of Miami Law Review
The government will often suspect a taxpayer of tax evasion if it discovers that the taxpayer's net worth has increased and that the taxpayer did not report the full amount of the increase as taxable income. If the government can establish a likely source for the increase, a jury will be permitted to infer that the taxpayer derived the increase from currently taxable and unreported income. In this article, the author discusses the origins, development, and varied applications of this "likely source inference." Then, after critically examining the constitutional underpinnings of the inference, the author argues that the inference is …
Taxation-Income Tax-Deductions For Alimony Payments Made Under Voluntary Agreement Of Separation, William R. Hewitt S. Ed.
Taxation-Income Tax-Deductions For Alimony Payments Made Under Voluntary Agreement Of Separation, William R. Hewitt S. Ed.
Michigan Law Review
Taxpayer and his wife voluntarily entered into a written agreement of separation. Pursuant to the agreement, taxpayer made periodic payments to his wife in discharge of his legal obligation of support. In his income tax return for 1943, taxpayer took the amount of tlie payments made for that year as a deduction from gross income under the authority of section 23(u) of the Internal Revenue Code. The commissioner disallowed the deduction and determined a tax deficiency. Upon petition to the Tax Court for a redetermination of the deficiency, the commissioner was upheld. On appeal, held, affirmed. Only alimony payments …