Autin v. Commissioner
United States Tax Court
L, a Louisiana corporation, was incorporated during 1974 because P wanted to help his son, S, become involved in business. One hundred shares of L stock were issued at L's incorporation, of which P received 51 shares and S received 49 shares.
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L, a Louisiana corporation, was incorporated during 1974 because P wanted to help his son, S, become involved in business. One hundred shares of L stock were issued at L's incorporation, of which P received 51 shares and S received 49 shares. At the time L was incorporated, P executed a "counter letter" which stated that P renounced any ownership interest in the 51 shares of stock issued to him and that the 51 shares had been acquired by P on account of S. From the time of L's incorporation until June 1988, P held himself out as the majority shareholder of L to the IRS, the Louisiana taxing…
1Opinion of the Court
Claude J. Autin, Petitioner v. Commissioner of Internal Revenue, Respondent
Autin v. Commissioner
Docket No. 4704-92
United States Tax Court
102 T.C. 760; 1994 U.S. Tax Ct. LEXIS 38; 102 T.C. No. 35;
June 14, 1994, Filed
An appropriate order will be issued.
L, a Louisiana corporation, was incorporated during 1974 because P wanted to help his son, S, become involved in business. One hundred shares of L stock were issued at L's incorporation, of which P received 51 shares and S received 49 shares. At the time L was incorporated, P executed a "counter letter" which stated that P renounced any ownership…
2Cases cited24 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- United States v. BoyleSupreme Court of the United States · 1985
- Higgins v. SmithSupreme Court of the United States · 1940
- Morgan v. CommissionerSupreme Court of the United States · 1940
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