Scott C. Rethorst, Appellant, v. Commissioner of Internal Revenue, Appellee.vehicle Research Corporation, Appellant, v. Commissioner of Internal Revenue, Appellee, 509 F.2d 623 (9th Cir. 1975)
Annotate this CaseWilliam J. Currer, Jr. (argued), Currer, Kayaian & Kakita, Los Angeles, Cal., for appellant.
Dennis M. Nonohue (argued), Tax Div., Internal Revenue Service, Washington, D.C., for appellee.
Before CARTER, TRASK and GOODWIN, Circuit Judges.
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.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.
