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No. 8908080
United States Court of Appeals for the Ninth Circuit
Rethorst v. Commissioner
No. 8908080 · Decided December 3, 1974
No. 8908080·Ninth Circuit · 1974·
FlawFinder last updated this page Apr. 2, 2026
Case Details
Court
United States Court of Appeals for the Ninth Circuit
Decided
December 3, 1974
Citation
No. 8908080
Disposition
See opinion text.
Full Opinion
OPINION 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.
Plain English Summary
OPINION 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.
Key Points
01OPINION 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.
02The facts are set out in detail in the Tax Court Memorandum.
03We 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
04The 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”.
Frequently Asked Questions
OPINION 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.
FlawCheck shows no negative treatment for Rethorst v. Commissioner in the current circuit citation data.
This case was decided on December 3, 1974.
Use the citation No. 8908080 and verify it against the official reporter before filing.