Stein v. Commissioner
United States Tax Court
Petitioner's decedent received the residue of his deceased wife's estate, and also received payments from a controlled corporation.
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Petitioner's decedent received the residue of his deceased wife's estate, and also received payments from a controlled corporation. In prior cases the payments from the corporation to petitioner's decedent and his wife which were not reported as income either by them or by the corporation were determined to be taxable income to the corporation and corporate distributions taxable to the recipients, and additions to tax for fraud were imposed upon all three petitioners therein. The deficiencies and additions thereto assessed against the wife and the corporation remain unpaid in whole or in…
1Opinion of the Court
OPINION.
FokRestek, Judge:
Respondent has determined liabilities against the petitioners as transferees as follows:
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The issues for consideration are as follows:(1) Is respondent estopped to assert transferee liability in Docket Nos. 69931 and 69932 by reason of an “election” to treat the transfers involved therein as taxable distributions in prior cases?(2) Were certain transfers by the National Thread Co., Inc., to its shareholders during the years 1943 to 1946, inclusive, and the transfer from Esther’s estate involved in Docket Nos. 69931, 70277, and 78991 made with intent to…
2Cases cited36 opinions
- North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
- Flora v. United StatesSupreme Court of the United States · 1960
- Commissioner v. SternSupreme Court of the United States · 1958
- Commissioner v. Gooch Milling & Elevator Co.Supreme Court of the United States · 1944
- Healy v. CommissionerSupreme Court of the United States · 1953
31 more not listed; retrieve them via the Exa API.
3Cited by74 opinions
- Mysse v. CommissionerUnited States Tax Court · 1972
- Joseph Edelson and Harriet Edelson v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1987
- Dolan v. CommissionerUnited States Tax Court · 1965
- Estate of Baumgardner v. CommissionerUnited States Tax Court · 1985
- United States v. 58th Street Plaza Theatre, Inc.District Court, S.D. New York · 1968
69 more not listed; retrieve them via the Exa API.