Ciaio v. Commissioner
United States Tax Court
Petitioner and two individuals equally owned all of the capital stock of a corporation that had been organized in 1948. About 1959 the two individuals became dissatisfied with the operation of the corporation and wanted to dispose of their stock.
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Petitioner and two individuals equally owned all of the capital stock of a corporation that had been organized in 1948. About 1959 the two individuals became dissatisfied with the operation of the corporation and wanted to dispose of their stock. On Sept. 28, 1959, they entered into a written agreement, as sellers, with the corporation, as buyer, to sell their stock to the corporation for a total of $ 150,000. Prior thereto the corporation had applied to a bank for a loan of that amount. The bank was willing to make the loan to the corporation provided petitioner be substituted in the stock…
1Opinion of the Court
Arundell, Judge:
Bespondent determined deficiencies in income tax for the calendar years 1959, 1960, and 1961 in the amounts of $73,726.57, $3,028.50, and $1,174.05, respectively. The deficiencies for 1960 and 1961 are not in controversy and not all of the adjustments made for the year 1959 are in controversy. The only errors assigned by petitioners are as follows:(a) The Commissioner erroneously determined that petitioner, Frank Ciaio, received a distribution of $150,000.00 from Melody Sh,oe Corporation during the calendar year 1959.(b) The Commissioner erroneously determined that the…
2Cases cited12 opinions
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Helvering v. F. & R. Lazarus & Co.Supreme Court of the United States · 1939
- Wall v. United StatesCourt of Appeals for the Fourth Circuit · 1947
- William J. Sullivan and Georgia K. Sullivan v. United StatesCourt of Appeals for the Eighth Circuit · 1966
- Decker v. CommissionerUnited States Tax Court · 1959
7 more not listed; retrieve them via the Exa API.
3Cited by46 opinions
- Yelencsics v. CommissionerUnited States Tax Court · 1980
- Hope v. CommissionerUnited States Tax Court · 1971
- Esmark, Inc. v. CommissionerUnited States Tax Court · 1988
- Stephens v. CommissionerUnited States Tax Court · 1973
- Bennett v. CommissionerUnited States Tax Court · 1972
41 more not listed; retrieve them via the Exa API.