Ramon Portillo and Dolores Portillo 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 a third-party Form 1099 did not, without 6 more, satisfy the presumption of correctness regarding alleged unreported income
• holding that \a court need not give effect to the presumption of correctness in a case involving unreported income if the Commissioner cannot present some predicate evidence supporting its determination\
• holding that in unreported income cases, the Commissioner must provide “some indicia that the taxpayer received unreported income” in order to shift the burden of proof to the taxpayer to disprove the Commissioner’s determination of unreported income
• explaining that the I.R.S. adequately linked the deficiency to the taxpayer by con- sidering information directly related to the taxpayer’s income tax return and investigating whether a deficiency indeed existed
• finding a deficiency notice valid where deficiency was computed by comparing taxpayer’s return against third-party reporting
• requiring the IRS to attempt to substantiate a disputed charge of unreported income by some means other than the naked assertion of the third-party reporter

Source: CourtListener parenthetical corpus (CC0).