Kloppenberg & Co. v. Commissioner
United States Tax Court
Held: Respondent's motions to amend the pleadings denied; individual petitioners received constructive dividends as a result of sale of property interest between related corporations; disallowance of portion of corporate petitioner's interest deduction sustained; individual petitioners did not realized ordinary income on sale of depreciable asset between related corporations; and assessment of deficiencies was not barred by statute of limitations.
1Opinion of the Court
KLOPPENBERG AND COMPANY, ET AL., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Kloppenberg & Co. v. Commissioner
Docket Nos. 14926-83, 14927-83, 14928-83, 14929-83, 14930-83, 14931-83, 14932-83, 14933-83, 14934-83.
United States Tax Court
T.C. Memo 1986-325; 1986 Tax Ct. Memo LEXIS 284; 51 T.C.M. (CCH) 1607; T.C.M. (RIA) 86325;
July 29, 1986.
Held: Respondent's motions to amend the pleadings denied; individual petitioners received constructive dividends as a result of sale of property interest between related corporations; disallowance of portion of corporate petitioner's interest…
2Cases cited40 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Knetsch v. United StatesSupreme Court of the United States · 1960
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- Union Carbide Foreign Sales Corp. v. CommissionerUnited States Tax Court · 2000
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