Perano v. Comm'r
United States Tax Court
In 1994 and 1996, Ps, the sole shareholders of AG, a controlled foreign corporation as defined in sec. 957, I.R.C., transferred to AG United States real property and notes secured by such property in exchange for private annuity agreements that provided for the future payment of monthly annuities to Ps for their remaining joint lives.
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In 1994 and 1996, Ps, the sole shareholders of AG, a controlled foreign corporation as defined in sec. 957, I.R.C., transferred to AG United States real property and notes secured by such property in exchange for private annuity agreements that provided for the future payment of monthly annuities to Ps for their remaining joint lives. For 1994-2001, AG accrued liabilities with respect to those agreements in amounts that, for 2001, exceeded income and, cumulatively, exceeded accumulated earnings and profits as of Dec. 31, 2001. Relying upon sec. 953, I.R.C., and the regulations thereunder, Ps…
1Opinion of the Court
DANTE AND SANDI PERANO, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Perano v. Comm'r
No. 5543-06
United States Tax Court
130 T.C. 93; 2008 U.S. Tax Ct. LEXIS 8; 130 T.C. No. 8;
May 7, 2008., Filed
In 1994 and 1996, Ps, the sole shareholders of AG, a controlled foreign corporation as defined in sec. 957, I.R.C., transferred to AG United States real property and notes secured by such property in exchange for private annuity agreements that provided for the future payment of monthly annuities to Ps for their remaining joint lives. For 1994-2001, AG accrued liabilities with respect to…
2Cases cited10 opinions
- Helvering v. Le GierseSupreme Court of the United States · 1941
- Amerco v. CommissionerUnited States Tax Court · 1991
- Amerco, Inc. Republic Insurance v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1992
- Dean v. Commissioner of Interna RevenueCourt of Appeals for the Third Circuit · 1951
- Patty v. HelveringCourt of Appeals for the Second Circuit · 1938
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