Cathy Miller Hardy v. Commissioner of Internal Revenue

How courts have described this case

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

• holding that third-party information returns were enough to establish the evidentiary foundation for the presumption of correctness to attach
• recognizing that, if government produces “some substantive evidence” of unreported income, burden shifts to taxpayer to establish that determination is arbitrary or erroneous
• describing the general burden of proof in deficiency cases

Source: CourtListener parenthetical corpus (CC0).