Dellacroce v. Commissioner
United States Tax Court
Based in part on information furnished by an informant, respondent determined that petitioner received a $ 100,000 labor racketeering payoff in 1965, which he failed to report as income.
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Based in part on information furnished by an informant, respondent determined that petitioner received a $ 100,000 labor racketeering payoff in 1965, which he failed to report as income. Respondent also determined that the per-share fair market value of 22,500 shares of stock received by petitioner in 1968 as a labor racketeering payoff, but not reported by him as income, was $ 4.875. Held: Following the Second Circuit's decision in Llorente v. Commissioner, 649 F.2d 152 (2d Cir. 1981), affg. in part and revg. and remanding in part 74 T.C. 260 (1980), the notice of deficiency for 1965 was…
1Opinion of the Court
Sterrett, Judge:
In these consolidated cases, respondent determined income tax deficiencies and additions to tax as follows:
Docket Additions to tax under No. Petitioner Year Deficiency Sec. 6653(b) Sec. 6654(a)
5895-77 Aniello Dellacroce and Mary Della- 1968 $80,109.47 1$40,054.74 croce
5896-77 Aniello Dellacroce 1965 54,731.00 27,366.00 $1,533
Respondent has now conceded the addition to tax for fraud under section 6653(b) for the year 1965. After this concession and other concessions by the parties, the primary issues remaining for decision are the following:(1) Whether petitioner, Aniello…
2Cases cited36 opinions
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- Hoffman v. United StatesSupreme Court of the United States · 1951
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- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
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