Legal Opinion

Silverman v. Commissioner

United States Tax Court

Decided February 20, 1996No. Docket No. 20324-89UnpublishedCited by 1 opinion

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

  1. Wichita Term. El. Co. v. Commissioner of Int. R.Court of Appeals for the Tenth Circuit · 1947
  2. United States v. StewartSupreme Court of the United States · 1940
  3. Joyce Purcell v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1987
  4. Purcell v. CommissionerUnited States Tax Court · 1986
  5. Bokum v. CommissionerUnited States Tax Court · 1990

11 more not listed; retrieve them via the Exa API.

3Cited by1 opinion

  1. Nancy Silverman and Estate of Sheldon Silverman, Deceased, Nancy Silverman v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1997

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