Rogers v. Commissioner of Internal Revenue

Tax Court did not err in determining that taxpayer had failed to report $984,655 of taxable income that taxpayer had received from S corporation wholly owned by taxpayer. Record failed to support taxpayer’s claim that disputed income had been held by taxpayer in trust for third-parties, where there was no documentation evidencing existence of trust, and where taxpayer had previously paid income tax on portion of disputed income, after claiming that said funds represented payment for legal services to S corporation.