United States v. Massei

U.S.

Court: Supreme Court of the United States

Citations: 355 U.S. 595, 2 L. Ed. 2d 517, 78 S. Ct. 495, 1 A.F.T.R.2d (RIA) 1004, 1958 U.S. LEXIS 1888, SCDB 1957-059

Decision Date: 3/3/1958

Docket Number: No. 98

Jurisdiction: U.S.

Bluebook Citation: United States v. Massei, 355 U.S. 595, 2 L. Ed. 2d 517, 78 S. Ct. 495, 1 A.F.T.R.2d (RIA) 1004, 1958 U.S. LEXIS 1888, SCDB 1957-059 (1958)

More Cases: U.S. decisions from 1958

Citation analytics

How this case sits in the citation network, derived from CiteLaw's graph of published opinions.

★Highly CitedTop 1% most-cited · cited by 210 decisions

210

Citing decisions

Authorities cited

Courts citing

Citations by decade

1950s1960s1970s1980s1990s2000s2010s2020s

Courts citing this case

Tax Ct.111

T.C.32

5th Cir.13

2d Cir.11

7th Cir.8

1st Cir.6

Most recently cited by10

2025United States v. Anthony Sabaini 7th Cir.
2019United States v. Tanco-Baez 1st Cir.
2015Robert L. Porter, Petitioner T.C.
2015Porter v. Comm'r Tax Ct.
2012Scott v. Comm'r Tax Ct.
2012Michael A. Scott, Petitioner T.C.
2012Jeffrey A. Roye, Petitioner T.C.
2012Roye v. Comm'r Tax Ct.
2011Allen Powerstein & Rita Powerstein Rosen, Petitioners T.C.
2011Powerstein v. Comm'r Tax Ct.

Cites 2 cases

Holland v. United States
Massei v. United States

Counts reflect decisions in the CiteLaw corpus and may lag very recent opinions.

Opinion

UNITED STATES v. MASSEI.

Judges

Mr. Justice Douglas would affirm the judgment below on the opinion of the Court of Appeals, 241 F. 2d 895, 900-901.

Attorneys

Roger Fisher argued the cause for the United States. With him on the brief were Solicitor General Rankin, Assistant Attorney General Rice and Joseph F. Goetten.
Richard Maguire argued the cause and filed a brief for respondent.

majority Per Curiam.

The Court of Appeals has based its remand in part on the absence of “proof of likely source,” which it regards as an “indispensable” element of the net worth method, citing Holland v. United States, 348 U. S. 121, in support of its conclusion. In Holland we held that proof of a likely source was “sufficient” to convict in a net worth case where the Government did not negative all the possible nontaxable sources of the alleged net worth increase. This was not intended to imply that proof of a likely source was necessary in every case. On the contrary, should all possible sources of nontaxable income be negatived, there would be no necessity for proof of a likely source. The above explanation must be taken into consideration in applying the Holland doctrine to this case. A new trial being permissible under the terms of the order of the Court of Appeals, we affirm its judgment.

Mr. Justice Douglas would affirm the judgment below on the opinion of the Court of Appeals, 241 F. 2d 895, 900-901.