In Brief
This case concerns the income tax assessment of a business conducted by family members sharing the same premises. The tax authority seized pronotes (promissory notes) during a survey, claiming they represented fully-disclosed income. However, the Department sought to include the full face value as concealed income. The Court upheld lower authorities' findings that examination of borrowers showed only 50% or less of the face value was actually advanced, and that any concealed income discovered should be distributed among all family members actively carrying on the same business. The Supreme Court dismissed the Department's appeal, finding no substantial question of law warranted interference."
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