Legal Opinion

Sperapani v. Commissioner

United States Tax Court

Decided April 30, 1964No. Docket No. 334-62Published

1. Petitioner carried on a reporting business as a sole proprietorship under the name of Columbia Reporting Co. He filed with the district director of internal revenue a timely notice of election to have his sole proprietorship taxed as a domestic corporation under section 1361, 1954 Code.

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1. Petitioner carried on a reporting business as a sole proprietorship under the name of Columbia Reporting Co. He filed with the district director of internal revenue a timely notice of election to have his sole proprietorship taxed as a domestic corporation under section 1361, 1954 Code. Petitioner also filed timely corporation income tax returns for the enterprise which contained statements that the returns were filed pursuant to section 1361. A statement of election as prescribed in the applicable regulation, T.D. 6124, was not filed with the district director. Held, petitioner complied…

1Opinion of the Court

Fred J. Sperapani and Cecelia Sperapani, Petitioners, v. Commissioner of Internal Revenue, Respondent

Sperapani v. Commissioner

Docket No. 334-62

United States Tax Court

42 T.C. 308; 1964 U.S. Tax Ct. LEXIS 109;

April 30, 1964, Filed

Decision will be entered under Rule 50.

1. Petitioner carried on a reporting business as a sole proprietorship under the name of Columbia Reporting Co. He filed with the district director of internal revenue a timely notice of election to have his sole proprietorship taxed as a domestic corporation under section 1361, 1954 Code. Petitioner also filed timely corporation…

Also in this document: Dissent.

2Cases cited32 opinions

  1. Helvering v. WinmillSupreme Court of the United States · 1938
  2. Cammarano v. United StatesSupreme Court of the United States · 1959
  3. Miles-Conley Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1949
  4. Sperapani v. CommissionerUnited States Tax Court · 1964
  5. Miles-Conley Co. v. CommissionerUnited States Tax Court · 1948

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