Legal Opinion

Dileo v. Comm'r

United States Tax Court

Decided June 24, 1991No. Docket Nos. 22366-86, 22367-86, 15778-87Published

P1 and P2 each owned 50 percent of P3, a C corporation, and served as its president and secretary/treasurer, respectively. P3 was engaged in the business of printing and lithography. P1 and P2 ran P3's day-to-day operations and maintained its books and records. P1 and P2 opened secret bank accounts and deposited a portion of P3's gross receipts into the accounts. P1 and P2 withdrew funds from the secret bank accounts.

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P1 and P2 each owned 50 percent of P3, a C corporation, and served as its president and secretary/treasurer, respectively. P3 was engaged in the business of printing and lithography. P1 and P2 ran P3's day-to-day operations and maintained its books and records. P1 and P2 opened secret bank accounts and deposited a portion of P3's gross receipts into the accounts. P1 and P2 withdrew funds from the secret bank accounts. P1 and P2 did not maintain any books or records reflecting transactions made with respect to the secret bank accounts. P3 did not report any of the gross receipts deposited into…

1Opinion of the Court

Joseph R. DiLeo and Mary A. DiLeo, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent

Dileo v. Comm'r

Docket Nos. 22366-86, 22367-86, 15778-87

United States Tax Court

96 T.C. 858; 1991 U.S. Tax Ct. LEXIS 55; 96 T.C. No. 42;

June 24, 1991, Filed

Decisions will be entered under Rule 155.

P1 and P2 each owned 50 percent of P3, a C corporation, and served as its president and secretary/treasurer, respectively. P3 was engaged in the business of printing and lithography. P1 and P2 ran P3's day-to-day operations and maintained its books and records. P1 and P2 opened secret bank accounts…

2Cases cited61 opinions

  1. Holland v. United StatesSupreme Court of the United States · 1955
  2. United States v. JanisSupreme Court of the United States · 1976
  3. Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
  4. Helvering v. TaylorSupreme Court of the United States · 1935
  5. Harisiades v. ShaughnessySupreme Court of the United States · 1951

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