Caracci v. Comm'r
United States Tax Court
Members of the C family wholly own three home health care organizations (P1, P2, and P3) exempt from Federal income taxes under sec. 501(c)(3), I.R.C. In 1995, the C family created three S corporations (S1, S2, and S3) and collectively received all of the resulting stock. P1, P2, and P3 then transferred all of their assets to S1, S2, and S3, respectively, in exchange for each transferee's assumption of the transferor's liabilities.
Read the full summary
Members of the C family wholly own three home health care organizations (P1, P2, and P3) exempt from Federal income taxes under sec. 501(c)(3), I.R.C. In 1995, the C family created three S corporations (S1, S2, and S3) and collectively received all of the resulting stock. P1, P2, and P3 then transferred all of their assets to S1, S2, and S3, respectively, in exchange for each transferee's assumption of the transferor's liabilities. R determined that the fair market value of the transferred assets substantially exceeded the consideration received in exchange. Accordingly, R determined S1, S2,…
1Opinion of the Court
MICHAEL T. CARACCI AND CINDY W. CARACCI, ET AL., Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Caracci v. Comm'r
No. 12481-99; No. 12482-99; No. 12483-99; No. 14711-99X; No. 17333-99; No. 17334-99; No. 17335-99; No. 17336-99X; No. 17337-99; No. 17338-99; No. 17339-99X; No. 17340-99; No. 17341-99; No. 17342-99
United States Tax Court
118 T.C. 379; 2002 U.S. Tax Ct. LEXIS 25; 118 T.C. No. 25;
May 22, 2002, Filed
Decisions will be entered for petitioners in docket Nos. 14711-99X, 17336-99X, and 17339-99X, and will be entered under Rule 155 in the remaining dockets.
APPENDIX
SEC. 4958.…
2Cases cited43 opinions
- Daubert v. Merrell Dow Pharmaceuticals, Inc.Supreme Court of the United States · 1993
- Kumho Tire Co. v. CarmichaelSupreme Court of the United States · 1999
- Helvering v. National Grocery Co.Supreme Court of the United States · 1938
- United States v. CartwrightSupreme Court of the United States · 1973
- Neonatology Assocs., P.A. v. Comm'rUnited States Tax Court · 2000
38 more not listed; retrieve them via the Exa API.