Magnon v. Commissioner
United States Tax Court
Held: 1. Individual petitioners, who were the sole shareholders of the corporate petitioner herein, received constructive dividends due to their corporation's performance of electrical contracting services on their separate personal properties where such work was performed primarily for their own benefit and without any expectation of repayment; 2. Intercorporate transfers of funds between the corporate petitioner and its sister corporation did not result in a constructive…
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Held: 1. Individual petitioners, who were the sole shareholders of the corporate petitioner herein, received constructive dividends due to their corporation's performance of electrical contracting services on their separate personal properties where such work was performed primarily for their own benefit and without any expectation of repayment; 2. Intercorporate transfers of funds between the corporate petitioner and its sister corporation did not result in a constructive dividend to the individual petitioners owning all the stock of both corporations where such transfers were made for…
1Opinion of the Court
Quealy, Judge:
The respondent determined the following deficiencies in income taxes and additions to the tax in these consolidated cases;
Raymond and Vera E. Magnon — Docket No. 1201-77
Deficiencies Addition to tax Addition to tax Calendar year in income tax sec. 6651(a)1 sec.6658(a)
1970. $80,818 0 $4,041
1971. 61,376 $15,344 3,069
1972 . 48,778 0 2,439
1973 . 260,202 0 13,010
Magnon Service Electric Corp. — Docket No. 1281-77
Deficiency Addition to tax
FYE Apr. SO— in income tax sec. 6653(a)
1970. $103,575.85 0
1971. 88,456.84 $4,422.84
1973. 16,187.47 809.37
Raymond and Vera E. Magnon, petitioners in…
2Cases cited28 opinions
- United States v. MitchellSupreme Court of the United States · 1971
- Electric & Neon, Inc. v. CommissionerUnited States Tax Court · 1971
- American Properties, Inc. v. CommissionerUnited States Tax Court · 1957
- Rosano v. CommissionerUnited States Tax Court · 1966
- Charles A. Sammons, Individually, and Estate of Rosine S. Sammons, Deceased, Charles A. Sammons, Independent v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1973
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3Cited by72 opinions
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- Hood v. CommissionerUnited States Tax Court · 2000
- Asphalt Products Co., Inc., Cross-Appellee v. Commissioner of Internal Revenue, Cross-AppellantCourt of Appeals for the Sixth Circuit · 1986
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