Arcia v. Commissioner
United States Tax Court
T.C. Memo. 1998-178 (1998)
Eduardo Macias had a large amount of cash, approximately $110,000, that he asked a succession of friends to hide for him. Eventually, in 1991, Elio Arcia (plaintiff) took possession of the cash for Macias. Arcia placed Macias’s money in a cooler in his garage, where he was also storing his own money. That same year, the city of Miami conducted a search and seizure at Arcia’s house and took approximately $200,000 from Arcia’s cooler. Arcia told the police that a portion of the money belonged to a friend. During later proceedings, Macias gave statements and signed an affidavit explaining that he had entrusted Arcia to store his money for safekeeping. Arcia did not include Macias’s money on his 1991 income-tax return. The Commissioner of Internal Revenue (the Commissioner) (defendant) determined a deficiency against Arcia, arguing that Arcia had failed to report the money he was holding for Macias as income. Macias petitioned the United States Tax Court for a redetermination.
Rule of Law
Holding and Reasoning (Jacobs, J.)
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