(DOWNLOAD) "Smith v. Commissioner of Internal Revenue" by United States Court of Appeals for the Fourth Circuit " eBook PDF Kindle ePub Free
eBook details
- Title: Smith v. Commissioner of Internal Revenue
- Author : United States Court of Appeals for the Fourth Circuit
- Release Date : January 15, 1991
- Genre: Law,Books,Professional & Technical,
- Pages : * pages
- Size : 61 KB
Description
Smith was served with a notice of deficiency regarding tax years 1984, 1985, and 1986. The IRS cited him with tax deficiencies totalling $229,334.29 and penalties totaling $243,727.85. In his petition for redetermination of the deficiency, Smith claimed that his income for the years in question was not properly calculated under the net worth method. He further claimed that, even if his income was correctly determined, the IRS erred in failing to allow him deductions for property forfeited to the government pursuant to 21 U.S.C. § 853. In the alternative, he claimed that because the forfeited property belonged to the government all along as a result of the relation back provision of the forfeiture statute, his income from drug transactions could not be included in his taxable income. He also claimed that the statute of limitations had run on tax year 1984, and that taxes and penalties from that year should not be assessed. Finally, he claimed that because he did not intend to defraud the government, the portion of penalties attributed to his intent to defraud should be stricken.
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