Manuel Cebollero 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.

• indicating that \the Commissioner always has the burden of persuasion as to the amount and existence of any deficiency\
• clarifying that “[w]here the taxpayer fails to keep or produce adequate records from which his income can be determined,”, the IRS may “resort to the best procedure available under the circumstances” to reconstruct the records (internal quotation marks and citation omitted)
• “If the taxpayer proves that the determination is arbitrary, the presumption of correctness vanishes.”

Source: CourtListener parenthetical corpus (CC0).