Legal Opinion

Kubik v. Commissioner

United States Tax Court

Decided March 12, 1974No. Docket No. 5960-68Unpublished

1. Held: Missouri Valley Distributors, Inc., a valid taxable entity, must include in income certain amounts paid to it or on its behalf by a lessee pursuant to the terms of a ground lease. 2. Held: A portion of each of the underpayments of tax that Missouri Valley Distributors, Inc. was required to show on its Federal income tax returns for each of the taxable years in issue was due to fraud. 3.Held: Petitioner is liable as a transferee of the assets of Missouri Valley…

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1. Held: Missouri Valley Distributors, Inc., a valid taxable entity, must include in income certain amounts paid to it or on its behalf by a lessee pursuant to the terms of a ground lease. 2. Held: A portion of each of the underpayments of tax that Missouri Valley Distributors, Inc. was required to show on its Federal income tax returns for each of the taxable years in issue was due to fraud. 3.Held: Petitioner is liable as a transferee of the assets of Missouri Valley Distributors, Inc. for the deficiencies determined by respondent. 4. Held: The statutory period for assessment and collection…

1Opinion of the Court

LEO KUBIK, TRANSFEREE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Kubik v. Commissioner

Docket No. 5960-68.

United States Tax Court

T.C. Memo 1974-62; 1974 Tax Ct. Memo LEXIS 257; 33 T.C.M. (CCH) 302; T.C.M. (RIA) 74062;

March 12, 1974, Filed.

1. Held: Missouri Valley Distributors, Inc., a valid taxable entity, must include in income certain amounts paid to it or on its behalf by a lessee pursuant to the terms of a ground lease.

2. Held: A portion of each of the underpayments of tax that Missouri Valley Distributors, Inc. was required to show on its Federal income tax returns for…

2Cases cited14 opinions

  1. Commissioner v. SunnenSupreme Court of the United States · 1948
  2. Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
  3. Beaver v. CommissionerUnited States Tax Court · 1970
  4. Commissioner v. SternSupreme Court of the United States · 1958
  5. Muste v. CommissionerUnited States Tax Court · 1961

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