Legal Opinion

BIAGGI v. COMMISSIONER

United States Tax Court

Decided February 11, 2000No. 16697-97UnpublishedCited by 1 opinion

P did not report gross income on account of the receipt of shares of W Corp. stock in 1983 and the sale of 25,000 W shares in 1985. P is collaterally estopped from contesting the facts established in his criminal case, United States v. Biaggi, 705 F. Supp. 864 (S.D.N.Y. 1988), including extortion, bribery, and receipt of an unlawful gratuity in connection with his demand and receipt of W shares, and filing false income tax returns for failing to report income from his…

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P did not report gross income on account of the receipt of shares of W Corp. stock in 1983 and the sale of 25,000 W shares in 1985. P is collaterally estopped from contesting the facts established in his criminal case, United States v. Biaggi, 705 F. Supp. 864 (S.D.N.Y. 1988), including extortion, bribery, and receipt of an unlawful gratuity in connection with his demand and receipt of W shares, and filing false income tax returns for failing to report income from his ownership of W shares. 1. HELD: The fair market value of the W shares was $ 11.20 a share; therefore, P omitted from gross…

1Opinion of the Court

MARIO BIAGGI and ESTATE OF MARIE BIAGGI, DECEASED, RICHARD BIAGGI, EXECUTOR, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

BIAGGI v. COMMISSIONER

No. 16697-97

United States Tax Court

T.C. Memo 2000-48; 2000 Tax Ct. Memo LEXIS 57; 79 T.C.M. (CCH) 1488;

February 11, 2000, Filed

Decision will be entered under Rule 155.

P did not report gross income on account of the receipt of

shares of W Corp. stock in 1983 and the sale of 25,000 W shares

in 1985. P is collaterally estopped from contesting the facts

established in his criminal case, United States v. Biaggi,

705 F. Supp. 864 (S.D.N.Y. 1988),…

2Cases cited19 opinions

  1. Spies v. United StatesSupreme Court of the United States · 1943
  2. Pallottini v. CommissionerUnited States Tax Court · 1988
  3. Joseph R. Dileo, Mary A. Dileo, Walter E. Mycek, Jr., Michele A. Mycek and Arcelo Reproduction Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1992
  4. Condor Merritt v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1962
  5. Recklitis v. CommissionerUnited States Tax Court · 1988

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

3Cited by1 opinion

  1. In re WylyUnited States Bankruptcy Court, N.D. Texas · 2016

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