Archie Dale Carson v. United States

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• “If the record contains no item of proof tending to show that the taxpayer was engaged in wagering activity during the period assessed, the Commissioner’s determination cannot prevail.”
• “This burden applies whether the proceeding is in Tax Court for redetermination of a deficiency or in district court upon a refund claim or a government counterclaim.”
• government reliance on simply a presumption of correctness untenable since it \would support the most arbitrary of assessments so long as the taxpayer found himself unable to prove a negative\
• reviewing factual findings by district court following bench trial

Source: CourtListener parenthetical corpus (CC0).