Dileo v. Comm'r
United States Tax Court
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
NlMS, Chief Judge:
Respondent determined the following deficiencies in and additions to petitioners’ Federal income tax:
Additions to tax
Sec. Sec. Sec. See.
Petitioners Year Deficiency 6653(b) 6653(b)(1) 6653(b)(2) 6661
Joseph R. 1978 $5,068.00 $2,534.00
and Mary 1979 10,635.37 5,317.69
A. DiLeo 1980 10,303.75 5,151.87
1981 11,157.51 5,578.75
1982 12,209.45 $6,104.72
Walter E. and 1978 4,681.00 2.340.50
Michele A. 1979 12,867.89 6,433.94
Mycek, Jr. 1980 11,405.99 5,703.00
1981 5,789.00 2.894.50
Additions to tax
Sec. Sec. Sec. Sec.
Petitioners Year Deficiency 6658(b) 6658(b)(1) 6658(b)(2) 6661
Arcelo 1978…
2Cases cited59 opinions
- Holland v. United StatesSupreme Court of the United States · 1955
- United States v. JanisSupreme Court of the United States · 1976
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Helvering v. TaylorSupreme Court of the United States · 1935
- Harisiades v. ShaughnessySupreme Court of the United States · 1951
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3Cited by6 opinions
- Cole v. CommissionerCourt of Appeals for the Seventh Circuit · 2011
- Kanter v. CommissionerCourt of Appeals for the Seventh Circuit · 2009
- In re WylyUnited States Bankruptcy Court, N.D. Texas · 2016
- Gagliardi v. United StatesUnited States Court of Federal Claims · 2008
- Dileo v. Comm'rUnited States Tax Court · 1991
1 more not listed; retrieve them via the Exa API.