Silverman v. Commissioner
United States Tax Court
H invested $ 100,000 in an arrangement, as a result of which a $ 1,600,000 Schedule C deduction was claimed on the 1981 tax return. W did not see or sign this tax return, but the parties agree that it was a joint tax return. As a result of H's income tax withholding and excess F.I.C.A. withholding, H's and W's 1981 joint tax return reported payments of $ 128,733, all of which was claimed as a refund.
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H invested $ 100,000 in an arrangement, as a result of which a $ 1,600,000 Schedule C deduction was claimed on the 1981 tax return. W did not see or sign this tax return, but the parties agree that it was a joint tax return. As a result of H's income tax withholding and excess F.I.C.A. withholding, H's and W's 1981 joint tax return reported payments of $ 128,733, all of which was claimed as a refund. In September 1982 respondent (R) refunded $ 74,360.39 plus interest by check, which H deposited in one of his individual checking accounts, and quickly spent. At the same time, R transferred the…
1Opinion of the Court
NANCY SILVERMAN AND ESTATE OF SHELDON SILVERMAN, DECEASED, NANCY SILVERMAN, EXECUTRIX, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Silverman v. Commissioner
Docket No. 20324-89
United States Tax Court
T.C. Memo 1996-69; 1996 Tax Ct. Memo LEXIS 147; 71 T.C.M. (CCH) 2127;
February 20, 1996, Filed
Decision will be entered in accordance with the parties' stipulations, as described supra in note 2.
H invested $ 100,000 in an arrangement, as a result of which a $ 1,600,000 Schedule C deduction was claimed on the 1981 tax return. W did not see or sign this tax return, but the parties agree…
2Cases cited16 opinions
- Wichita Term. El. Co. v. Commissioner of Int. R.Court of Appeals for the Tenth Circuit · 1947
- United States v. StewartSupreme Court of the United States · 1940
- Joyce Purcell v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1987
- Purcell v. CommissionerUnited States Tax Court · 1986
- Bokum v. CommissionerUnited States Tax Court · 1990
11 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Nancy Silverman and Estate of Sheldon Silverman, Deceased, Nancy Silverman v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1997