Legal Opinion

Rotolo v. Commissioner

United States Tax Court

Decided June 22, 1987No. Docket Nos. 8048-85, 8116-85, 8117-85, 8328-85, 8329-85, 8330-85, 8337-85PublishedCited by 29 opinions

D, a closely held corporation engaged in the manufacturing business, was liquidated in 1975. It used the completed contract method to report its income, and in computing its gross profits for its final taxable year, D included in gross receipts the advance payments which it had received under certain incomplete long-term contracts and offset the costs of inventory which it had on hand at the end of such year.

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D, a closely held corporation engaged in the manufacturing business, was liquidated in 1975. It used the completed contract method to report its income, and in computing its gross profits for its final taxable year, D included in gross receipts the advance payments which it had received under certain incomplete long-term contracts and offset the costs of inventory which it had on hand at the end of such year. Shortly before the liquidation, the principal stockholder of D transferred stock to three employees of D in recognition of their services for D. Held: 1. The Commissioner's disallowance…

1Opinion of the Court

SIMPSON, Judge:

The Commissioner determined the following deficiencies in the petitioners’ Federal income taxes and the following liabilities against the petitioners as transferees of corporate assets:

Petitioner Taxable year Deficiency Liability

Louis S. Rotolo and Dorothy R. Rotolo 1976 $5,571

James B. Wilson 4/1/75 to 2/13/76 $85,265

Thomas J. Golab and Ivalee N. Golab 1976 4,242

Louis S. Rotolo 4/1/75 to 2/13/76 85,265

James B. Wilson 1976 5,817

Robert S. Ledley 4/1/75 to 2/13/76 518,465

Thomas J. Golab 4/1/75 to 2/13/76 78,708

After concessions by the parties, the issues for decision are: (1)…

2Cases cited40 opinions

  1. United States v. AndersonSupreme Court of the United States · 1926
  2. Lucas v. American Code Co.Supreme Court of the United States · 1930
  3. Botany Worsted Mills v. United StatesSupreme Court of the United States · 1929
  4. Thor Power Tool Co. v. CommissionerSupreme Court of the United States · 1979
  5. Brown v. HelveringSupreme Court of the United States · 1934

35 more not listed; retrieve them via the Exa API.

3Cited by29 opinions

  1. Hamilton Industries, Inc. v. CommissionerUnited States Tax Court · 1991
  2. Thomas v. CommissionerUnited States Tax Court · 1989
  3. Bank One Corp. v. Comm'rUnited States Tax Court · 2003
  4. RLC Indus. Co. v. CommissionerUnited States Tax Court · 1992
  5. Berger v. CommissionerUnited States Tax Court · 1996

24 more not listed; retrieve them via the Exa API.

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