VERDEV v. DEPARTMENT OF REVENUE

No. 147.

53 Wis.2d 585 (1972)

193 N.W.2d 641

VERDEV, Respondent, v. DEPARTMENT OF REVENUE, Appellant.

Supreme Court of Wisconsin.

Decided February 1, 1972.


Attorney(s) appearing for the Case

For the appellant the cause was argued by E. Weston Wood, assistant attorney general, with whom on the briefs was Robert W. Warren, attorney general.

For the respondent there was a brief by Godfrey & Kahn, S. C., attorneys, and John M. Byers, James Ward Rector, Jr., and James Ward Rector of counsel, all of Milwaukee, and oral argument by James Ward Rector, Jr.


ROBERT W. HANSEN, J.

"If you would argue with me," said Voltaire, "define your terms." In reviewing an unreported income case involving the net worth approach, it is well to begin with an explanation of what the net worth approach involves. Fortunately, a concise definition of the concept is available:

"In a typical net worth prosecution, the Government, having concluded that the taxpayer's records are inadequate as a basis for determining income tax liability...

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