Legal Opinion

Clark v. Commissioner

United States Tax Court

Decided July 17, 1957No. Docket Nos. 48542-48544UnpublishedCited by 23 opinions

Petitioner Gene O. Clark, president and majority stockholder of Gene Clark, Inc., from April 23, 1946, through March 1, 1949, inclusive, was the dominating factor in conducting and controlling its corporate affairs. The corporation received substantial amounts of taxable income from unrecorded sales which it failed to report on its returns. Petitioner withheld and diverted to his own purposes substantial amounts out of the proceeds of such unreported sales.

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Petitioner Gene O. Clark, president and majority stockholder of Gene Clark, Inc., from April 23, 1946, through March 1, 1949, inclusive, was the dominating factor in conducting and controlling its corporate affairs. The corporation received substantial amounts of taxable income from unrecorded sales which it failed to report on its returns. Petitioner withheld and diverted to his own purposes substantial amounts out of the proceeds of such unreported sales. Held: 1. Petitioners realized unreported income from informal or constructive dividends from Gene Clark, Inc., for the calendar years…

1Opinion of the Court

Gene O. Clark v. Commissioner. Faye Clark v. Commissioner. Gene O. Clark and Faye Clark, Husband and Wife v. Commissioner.

Clark v. Commissioner

Docket Nos. 48542-48544.1

United States Tax Court

T.C. Memo 1957-129; 1957 Tax Ct. Memo LEXIS 120; 16 T.C.M. (CCH) 555; T.C.M. (RIA) 57129;

July 17, 1957

Petitioner Gene O. Clark, president and majority stockholder of Gene Clark, Inc., from April 23, 1946, through March 1, 1949, inclusive, was the dominating factor in conducting and controlling its corporate affairs. The corporation received substantial amounts of taxable income from unrecorded sales which…

2Cases cited15 opinions

  1. Helvering v. TaylorSupreme Court of the United States · 1935
  2. Gano v. CommissionerUnited States Board of Tax Appeals · 1930
  3. Imburgia v. CommissionerUnited States Tax Court · 1954
  4. L. Schepp Co. v. CommissionerUnited States Board of Tax Appeals · 1932
  5. Baird v. CommissionerUnited States Tax Court · 1955

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

3Cited by23 opinions

  1. Gene O. Clark and Faye Clark v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1959
  2. Olive v. CommissionerUnited States Tax Court · 2012
  3. TG Mo. Corp. v. Comm'rUnited States Tax Court · 2009
  4. Hewlett-Packard Co. v. Comm'rUnited States Tax Court · 2012
  5. Boyd Gaming Corp. v. CommissionerUnited States Tax Court · 1997

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

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