Hutcherson v. Commissioner
United States Tax Court
In 1970 and 1971, H owned and operated liquor stores. In 1971, H's liquor licenses expired, and he began to operate two liquor stores in O's name, using O's liquor licenses. O received none of the income produced by the stores, but he reported a portion of such income on his returns for 1971 and 1972. During 1971, H became concerned that his creditors, including the IRS, might obtain his real properties.
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In 1970 and 1971, H owned and operated liquor stores. In 1971, H's liquor licenses expired, and he began to operate two liquor stores in O's name, using O's liquor licenses. O received none of the income produced by the stores, but he reported a portion of such income on his returns for 1971 and 1972. During 1971, H became concerned that his creditors, including the IRS, might obtain his real properties. He executed and recorded a large number of deeds to the properties to D, B, P, and his son, G. The properties were to remain subject to the control of H.H. and W did not file Federal income…
1Opinion of the Court
GEORGE E. HUTCHERSON, JR., ET AL., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Hutcherson v. Commissioner
Docket Nos. 1337-77, 6659-79, 6660-79, 6661-79.
United States Tax Court
T.C. Memo 1984-165; 1984 Tax Ct. Memo LEXIS 513; 47 T.C.M. (CCH) 1421; T.C.M. (RIA) 84165;
April 2, 1984.
In 1970 and 1971, H owned and operated liquor stores. In 1971, H's liquor licenses expired, and he began to operate two liquor stores in O's name, using O's liquor licenses. O received none of the income produced by the stores, but he reported a portion of such income on his returns for 1971 and 1972.…
2Cases cited42 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Helvering v. CliffordSupreme Court of the United States · 1940
- Lucas v. EarlSupreme Court of the United States · 1930
- Helvering v. HorstSupreme Court of the United States · 1940
37 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Cebollero v. CommissionerUnited States Tax Court · 1990