Lesly Cohen 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, even if the Commissioner’s determination to disallow all COGS is “harsh and unrealistic”, any estimate under Cohan “must be [made] upon the basis of a finding of fact (which may be based upon approximations)”
• holding that, even if the Commissioner’s determination to disallow all COGS is “harsh and unrealistic”, any estimate under Cohan “must be * * * [made] upon the basis of a finding of fact (which may be based upon approximations)”
• holding that when the taxpayer has shown the determination to be arbitrary and excessive, the burden of persuasion shifts to the Commissioner to prove the correct amount of tax owed and the presumption as to the correctness of the Commissioner's determination is out of the case
• holding that when the taxpayer has shown the determination to be arbitrary and excessive, the burden of persuasion shifts to the Commissioner to prove the correct amount of tax owed and the presumption as to the correctness of the Commissioner’s determination is out of the case

Source: CourtListener parenthetical corpus (CC0).