Edward B. Adams v. Commissioner of Internal Revenue
456 F.2d 259·29 A.F.T.R.2d (RIA) 437·1972 U.S. App. LEXIS 11930
United States Court of Appeals for the Ninth CircuitJanuary 10, 197271-1725California72 words
Opinion
The decision of the Tax Court sustaining the Commissioner’s income tax deficiency assessment is affirmed.
The theory of the deficiency was that Adams devoted to his own use moneys belonging to the estate of his deceased mother. Even though nothing was earned, it is the theory of the income tax law that the tax collector can share such conversions.
An examination of the record indicates the Commissioner sustained his burden of proof.