Apicella v. Commissioner
United States Tax Court
For several years prior to 1933, petitioner Salvatore Apicella engaged in the sale and manufacture of furniture as a sole proprietor, during which time his wife, Rachel, contributed some capital and services. In 1933 the business was incorporated. All the stock of the corporation, consisting of 200 shares, was issued to Salvatore who, in 1936, transferred 100 of the shares to Rachel.
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For several years prior to 1933, petitioner Salvatore Apicella engaged in the sale and manufacture of furniture as a sole proprietor, during which time his wife, Rachel, contributed some capital and services. In 1933 the business was incorporated. All the stock of the corporation, consisting of 200 shares, was issued to Salvatore who, in 1936, transferred 100 of the shares to Rachel. On December 23, 1936, Salvatore created a trust for the benefit of petitioners' three children aged 14, 11, and 7. He transferred 60 shares of the 100 held by him to the trust. In 1937 Rachel transferred 34 of…
1Opinion of the Court
Salvatore Apicella, et al., 1 Petitioners, v. Commissioner of Internal Revenue, Respondent
Apicella v. Commissioner
Docket Nos. 56362, 56363, 56364
United States Tax Court
28 T.C. 979; 1957 U.S. Tax Ct. LEXIS 119;
August 9, 1957, Filed
Decisions will be entered under Rule 50.
For several years prior to 1933, petitioner Salvatore Apicella engaged in the sale and manufacture of furniture as a sole proprietor, during which time his wife, Rachel, contributed some capital and services. In 1933 the business was incorporated. All the stock of the corporation, consisting of 200 shares, was issued to…
2Cases cited14 opinions
- Helvering v. CliffordSupreme Court of the United States · 1940
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- Hash v. COMMISSIONER OF INTERNAL REVENUECourt of Appeals for the Fourth Circuit · 1945
- Feldman v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1950
- Feldman v. CommissionerUnited States Tax Court · 1950
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