Gerald J. Rapp and Mary H. Rapp 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 once the Government introduces evidence linking the taxpayer with income producing activity, the burden shifts to the taxpayer to establish that the deficiency determination is arbitrary or erroneous
• defining the Commissioner's \initial burden\ to require the introduction of \some evidence linking the taxpayer with income-producing activity\
• “While these records reflect that the IRS had before it information linking the Rapps with income-producing activities, including employment, the sale of their residence, and involvement in a business, that underlying information does not itself appear in the record.”
• law partnership is not third-party recordkeeper as defined by section 7609
• \The taxpayer has the burden of proof to substantiate claimed deductions.\

Source: CourtListener parenthetical corpus (CC0).