Recklitis v. Commissioner
United States Tax Court
R determined deficiencies in P's taxable income resulting from adjustments related to P's dealings with his own closely held corporation and with another publicly held corporation of which he was both an officer and a director. Held, P's misappropriation of funds through means of several land sales was properly includable in gross income.
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R determined deficiencies in P's taxable income resulting from adjustments related to P's dealings with his own closely held corporation and with another publicly held corporation of which he was both an officer and a director. Held, P's misappropriation of funds through means of several land sales was properly includable in gross income. Held, further, P failed to adequately account under sec. 274, I.R.C. 1954, to his employer regarding business expenses which were reimbursed. Held, further: P's transfer of title to appreciated stock to a closely held corporation immediately before…
1Opinion of the Court
Christopher P. Recklitis, Petitioner v. Commissioner of Internal Revenue, Respondent
Recklitis v. Commissioner
Docket No. 24351-84
United States Tax Court
91 T.C. 874; 1988 U.S. Tax Ct. LEXIS 137; 91 T.C. No. 55;
November 7, 1988; As amended November 22, 1988 November 7, 1988, Filed
Decision will be entered under Rule 155.
R determined deficiencies in P's taxable income resulting from adjustments related to P's dealings with his own closely held corporation and with another publicly held corporation of which he was both an officer and a director. Held, P's misappropriation of funds through means of…
2Cases cited58 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Holland v. United StatesSupreme Court of the United States · 1955
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Gregory v. HelveringSupreme Court of the United States · 1935
- Spies v. United StatesSupreme Court of the United States · 1943
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