Graf v. Commissioner
United States Tax Court
Petitioner Mohammad Shafi a cash basis taxpayer, is a doctor practicing medicine in Wisconsin. In 1977, petitioner entered into a tax shelter promoted by the International Monetary Exchange (IME), a Panamanian corporation, wherein he purported to provide dredging services in Panama. Petitioner paid $ 40,000 to a local subcontractor to do the actual work. IME allegedly advanced $ 30,000 on behalf of petitioner to the subcontractor.
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Petitioner Mohammad Shafi a cash basis taxpayer, is a doctor practicing medicine in Wisconsin. In 1977, petitioner entered into a tax shelter promoted by the International Monetary Exchange (IME), a Panamanian corporation, wherein he purported to provide dredging services in Panama. Petitioner paid $ 40,000 to a local subcontractor to do the actual work. IME allegedly advanced $ 30,000 on behalf of petitioner to the subcontractor. Thus, petitioner paid $ 10,000 in cash and issued a $ 30,000 promissory note to IME. The note was payable only out of profits from the sale of oceanfront lots…
1Opinion of the Court
Werner Graf and Marguerite Graf, Petitioners v. Commissioner of Internal Revenue, Respondent; Mohammad and Rashida Shafi, Petitioners v. Commissioner of Internal Revenue, Respondent
Graf v. Commissioner
Docket Nos. 7888-80, 9149-80
United States Tax Court
80 T.C. 944; 1983 U.S. Tax Ct. LEXIS 78; 80 T.C. No. 50;
May 18, 1983, Filed
Petitioner Mohammad Shafi a cash basis taxpayer, is a doctor practicing medicine in Wisconsin. In 1977, petitioner entered into a tax shelter promoted by the International Monetary Exchange (IME), a Panamanian corporation, wherein he purported to provide dredging services…
2Cases cited38 opinions
- Adickes v. S. H. Kress & Co.Supreme Court of the United States · 1970
- Crane v. CommissionerSupreme Court of the United States · 1947
- Jacklin v. CommissionerUnited States Tax Court · 1982
- Estate of Charles T. Franklin, Deceased v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1976
- Eckert v. BurnetSupreme Court of the United States · 1931
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