affirming Tax Court decision allowing inadmissible statements to support the reasonableness of an IRS agent's actions
How later courts described this case
- affirming Tax Court decision allowing inadmissible statements to support the reasonableness of an IRS agent's actions
- "elaborate construct set out in the deficiency notice ... turns out to be sheer gossamer”
- “The Commissioner’s determination may often rest upon hearsay or other inadmissible evidence.”
- unreported income from drug trafficking activities
Written by the judges who cited it.
The opinion
Irwin, J., concurring: As the trier of facts in this case, I agree with the majority’s findings of fact and in its conclusion that petitioner was not a credible witness. I also concur in the result reached by the majority.