Legal Opinion

Astone v. Commissioner

United States Tax Court

Decided December 15, 1983No. Docket Nos. 2095-76, 2107-76, 2108-76Unpublished

Held: 1. Anthony and Dorothi Astone are liable for the addition to tax for fraud for their taxable years 1966 through 1971, inclusive. 2. Except to the extent conceded by respondent, Anthony and Dorothi Astone received constructive dividends from Newburgh during the taxable years 1966 through 1971, as determined in the notice of deficiency. 3. Dorothi Astone received unreported rental income during her taxable years 1966 through 1971 in the amounts determined by respondent.…

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Held: 1. Anthony and Dorothi Astone are liable for the addition to tax for fraud for their taxable years 1966 through 1971, inclusive. 2. Except to the extent conceded by respondent, Anthony and Dorothi Astone received constructive dividends from Newburgh during the taxable years 1966 through 1971, as determined in the notice of deficiency. 3. Dorothi Astone received unreported rental income during her taxable years 1966 through 1971 in the amounts determined by respondent. 4. Anthony Astone received unreported compensation income from Newburgh during his 1966 and 1969 taxable years in the…

1Opinion of the Court

ANTHONY ASTONE and DOROTHI ASTONE, ET AL., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Astone v. Commissioner

Docket Nos. 2095-76, 2107-76, 2108-76.

United States Tax Court

T.C. Memo 1983-747; 1983 Tax Ct. Memo LEXIS 37; 47 T.C.M. (CCH) 632; T.C.M. (RIA) 83747;

December 15, 1983.

Held:

1. Anthony and Dorothi Astone are liable for the addition to tax for fraud for their taxable years 1966 through 1971, inclusive.

2. Except to the extent conceded by respondent, Anthony and Dorothi Astone received constructive dividends from Newburgh during the taxable years 1966 through 1971, as…

2Cases cited38 opinions

  1. Holland v. United StatesSupreme Court of the United States · 1955
  2. Spies v. United StatesSupreme Court of the United States · 1943
  3. Stone v. CommissionerUnited States Tax Court · 1971
  4. Gajewski v. CommissionerUnited States Tax Court · 1976
  5. Beaver v. CommissionerUnited States Tax Court · 1970

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