Stein v. Commissioner
United States Tax Court
National Thread Company, Inc., (NTC), was organized by the father of Esther M. Stein in 1913. Esther was NTC's sole stockholder from 1916 until January 27, 1944, on which date she transferred all her stock to Samuel Stein, her husband.
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National Thread Company, Inc., (NTC), was organized by the father of Esther M. Stein in 1913. Esther was NTC's sole stockholder from 1916 until January 27, 1944, on which date she transferred all her stock to Samuel Stein, her husband. Esther died on March 27, 1944. Prior to the years in issue (1942-1945) Esther directed NTC's affairs and, although she remained active until her death, Samuel took an increasingly greater part, and was dominant (as between himself and Esther), in running NTC from about 1942 on. Carolina Thread Mills (Carolina) was a business name registered by Samuel. 1. It was…
1Opinion of the Court
OPINION.
Black, Judge:
Issues 1, 0, and 3.
We first consider to wfiat extent and to whom certain stipulated unreported sales and certain alleged “unexplained” or “unidentified” bank deposits represent unreported taxable income.
1. The parties stipulated that during the years 1942 through 1945, sales totaling $156,203.63 were made in the names of Samuel, Carolina, and NTC (as fully detailed in our Findings of Fact), that the proceeds thereof were received by Samuel and/or Esther, and that such sales were not reported for tax purposes by any of the petitioners herein. Petitioners contend that those…
2Cases cited35 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Spies v. United StatesSupreme Court of the United States · 1943
- Helvering v. MitchellSupreme Court of the United States · 1938
- United States v. AndersonSupreme Court of the United States · 1926
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
30 more not listed; retrieve them via the Exa API.
3Cited by87 opinions
- Gene O. Clark and Faye Clark v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1959
- Stein v. CommissionerUnited States Tax Court · 1962
- F. W. Drybrough v. Commissioner of Internal Revenue, L. N. Simpson v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1956
- James Armour, Inc. v. CommissionerUnited States Tax Court · 1964
- Wilson v. CommissionerUnited States Tax Court · 1981
82 more not listed; retrieve them via the Exa API.