Scott C. Rethorst v. Commissioner of Internal Revenue, Vehicle Research Corporation v. Commissioner of Internal Revenue

Ninth Circuit

Scott C. Rethorst v. Commissioner of Internal Revenue, Vehicle Research Corporation v. Commissioner of Internal Revenue

509 F.2d 623

CourtCourt of Appeals for the Ninth Circuit

DecidedJune 2, 1975

Docket73--1925

StatusPublished

This text of 509 F.2d 623 (Scott C. Rethorst v. Commissioner of Internal Revenue, Vehicle Research Corporation v. Commissioner of Internal Revenue) is published on Counsel Stack Legal Research, covering Court of Appeals for the Ninth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Scott C. Rethorst v. Commissioner of Internal Revenue, Vehicle Research Corporation v. Commissioner of Internal Revenue, 509 F.2d 623 (9th Cir. 1975).

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Opinion

509 F.2d 623

75-1 USTC P 9111

Scott C. RETHORST, Appellant,
v.
COMMISSIONER OF INTERNAL REVENUE, Appellee.
VEHICLE RESEARCH CORPORATION, Appellant,
v.
COMMISSIONER OF INTERNAL REVENUE, Appellee.

Nos. 73--1925, 73--1926.

United States Court of Appeals,
Ninth Circuit.

Dec. 3, 1974.
Rehearing Denied Jan. 7, 1975.
Certiorari Denied June 2, 1975.
See 95 S.Ct. 2404.

William 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.

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509 F.2d 623

75-1 USTC P 9111

Scott C. RETHORST, Appellant,
v.
COMMISSIONER OF INTERNAL REVENUE, Appellee.
VEHICLE RESEARCH CORPORATION, Appellant,
v.
COMMISSIONER OF INTERNAL REVENUE, Appellee.

Nos. 73--1925, 73--1926.

United States Court of Appeals,
Ninth Circuit.

Dec. 3, 1974.
Rehearing Denied Jan. 7, 1975.
Certiorari Denied June 2, 1975.
See 95 S.Ct. 2404.

William 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.

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509 F.2d 623, Counsel Stack Legal Research, https://law.counselstack.com/opinion/scott-c-rethorst-v-commissioner-of-internal-revenue-vehicle-research-ca9-1975.