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LLORENTE v. C. I. R.

No. 857 — Docket 81-4320.

649 F.2d 152 (1981)

Raul LLORENTE, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Second Circuit.

Decided May 14, 1981.

Attorney(s) appearing for the Case

Leonard Bailin, New York City, for petitioner-appellant.

Anthony Ilardi, Jr., Atty. Tax Division, Dept. of Justice, Washington, D.C. (John F. Murray, acting Asst. Atty. Gen. Michael L. Paup, Wynette J. Hewett, Attys., Tax Division, Dept. of Justice, Washington, D.C., of counsel), for respondent-appellee.

Before FRIENDLY, MANSFIELD and KEARSE, Circuit Judges.

MANSFIELD, Circuit Judge:

Raul Llorente, a taxpayer, appeals from a decision of the United States Tax Court filed May 13, 1980, upholding with modifications a statutory Notice of Deficiency issued by the Commissioner of Internal Revenue (Commissioner) pursuant to §§ 6212, 6651(a), 6653(a) and 6654(a), Internal Revenue Code of 1954, which, using the expenditures method to reconstruct Llorente's income for the year 1974, claimed that he had unreported income...

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