Edelson v. Commissioner
United States Tax Court
J filed Forms 1040 for 1975, 1976 and 1977 which contained no information as to his income, deductions or credits for those years. J claimed on these forms that only dollars of gold and silver are taxable. In 1976, J transferred his one-half interest in two parcels of real estate to H, his wife, for inadequate consideration. Held, income tax deficiencies and additions to tax under section 6653(b), I.R.C., and section 6654, I.R.C., sustained.
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J filed Forms 1040 for 1975, 1976 and 1977 which contained no information as to his income, deductions or credits for those years. J claimed on these forms that only dollars of gold and silver are taxable. In 1976, J transferred his one-half interest in two parcels of real estate to H, his wife, for inadequate consideration. Held, income tax deficiencies and additions to tax under section 6653(b), I.R.C., and section 6654, I.R.C., sustained. Held further, H is liable for J's tax liabilities and additions to tax to the extent of $74,550 as a transferee of J's assets.
1Opinion of the Court
HARRIET EDELSON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent; JOSEPH EDELSON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Edelson v. Commissioner
Docket Nos. 14143-82, 14145-82.
United States Tax Court
T.C. Memo 1986-223; 1986 Tax Ct. Memo LEXIS 385; 51 T.C.M. (CCH) 1109; T.C.M. (RIA) 86223;
June 3, 1986.
J filed Forms 1040 for 1975, 1976 and 1977 which contained no information as to his income, deductions or credits for those years. J claimed on these forms that only dollars of gold and silver are taxable. In 1976, J transferred his one-half interest in two parcels of…
2Cases cited18 opinions
- Holland v. United StatesSupreme Court of the United States · 1955
- Gajewski v. CommissionerUnited States Tax Court · 1976
- Otsuki v. CommissionerUnited States Tax Court · 1969
- Chris D. Stoltzfus and Irma H. Stoltzfus v. United StatesCourt of Appeals for the Third Circuit · 1968
- Commissioner v. SternSupreme Court of the United States · 1958
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