Haag v. Commissioner
United States Tax Court
P, a physician, assigned his interest in a medical partnership and other businesses to P.C., a one-man professional service corporation. P entered into an employment agreement with P.C. and performed medical services on behalf of P.C. P received either no salary or minimal salary from P.C. P took insubstantial sums of cash directly from the medical partnership and made and received cash advances to and from the P.C.
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P, a physician, assigned his interest in a medical partnership and other businesses to P.C., a one-man professional service corporation. P entered into an employment agreement with P.C. and performed medical services on behalf of P.C. P received either no salary or minimal salary from P.C. P took insubstantial sums of cash directly from the medical partnership and made and received cash advances to and from the P.C. R sought to allocate P.C.'s medical partnership income to P pursuant to sec. 61, the assignment of income doctrine and sec. 482, I.R.C. 1954. Held, P.C., not P, controlled the…
1Opinion of the Court
WILLIAMS, Judge: *
The Commissioner determined deficiencies in petitioner’s Federal income tax as follows:
Year Deficiency
1979 .$94,060.30
1980 . 72,057.91
1981 . 84,240.17
The issues we must decide are (1) whether certain income reported by petitioner’s closely held corporation during the years in issue is taxable to petitioner pursuant to section 611 and the assignment of income doctrine; and (2) whether such income is allocable to petitioner pursuant to section 482.
FINDINGS OF FACT
All of the facts have been stipúlated and, except as noted (see notes 2 and 3 infra), are so found. Petitioner…
2Cases cited29 opinions
- Lucas v. EarlSupreme Court of the United States · 1930
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- Greenberg's Express, Inc. v. CommissionerUnited States Tax Court · 1974
- Vercio v. CommissionerUnited States Tax Court · 1980
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