Western Products Co. v. Commissioner
United States Tax Court
1. In July 1946, the petitioners instituted an action against Wilbur F. Denious for an accounting. For a number of years prior thereto Denious had been president, treasurer and managing head of, and attorney for Western Products, Tivoli, and another corporation, in all of which Mrs. Vichey had been the principal stockholder and in which she was the sole stockholder when the action was instituted.
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1. In July 1946, the petitioners instituted an action against Wilbur F. Denious for an accounting. For a number of years prior thereto Denious had been president, treasurer and managing head of, and attorney for Western Products, Tivoli, and another corporation, in all of which Mrs. Vichey had been the principal stockholder and in which she was the sole stockholder when the action was instituted. Denious also had been an executor and trustee of and attorney for certain estates of which Mrs. Vichey was beneficiary. In addition, Denious had been her attorney and confidential adviser for many…
1Opinion of the Court
Withey, Judge:
The respondent determined deficiencies in the income tax of the petitioners as follows:
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Issues for determination are tlie correctness of the respondent’s action (1) in determining the amounts of taxable income received by petitioners in 1950 as a result of a court judgment entered and paid during that year; (2) in including in the income of the Western Products Company for 1950 the amount of a check it had received in 1945; (3) in determining that a portion of the payments made in 1949 and 1950 by Lo Paine Good Vichey and the Western Products Company, respectively,…
2Cases cited16 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
- North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
- Commissioner v. WilcoxSupreme Court of the United States · 1946
- Raytheon Production Corp. v. Commissioner of Int. Rev.Court of Appeals for the First Circuit · 1944
11 more not listed; retrieve them via the Exa API.
3Cited by41 opinions
- Harrison E. Spangler and Myrtle B. Spangler v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1963
- Fono v. CommissionerUnited States Tax Court · 1982
- Denver & Rio Grande Western Railroad Company v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1960
- Denver & R. G. W. R. Co. v. CommissionerUnited States Tax Court · 1959
- Kemper v. CommissionerUnited States Tax Court · 1958
36 more not listed; retrieve them via the Exa API.