Legal Opinion

Hutcherson v. Commissioner

United States Tax Court

Decided April 2, 1984No. Docket Nos. 1337-77, 6659-79, 6660-79, 6661-79UnpublishedCited by 1 opinion

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.

Read the full summary

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

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Commissioner v. SunnenSupreme Court of the United States · 1948
  3. Helvering v. CliffordSupreme Court of the United States · 1940
  4. Lucas v. EarlSupreme Court of the United States · 1930
  5. Helvering v. HorstSupreme Court of the United States · 1940

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

3Cited by1 opinion

  1. Cebollero v. CommissionerUnited States Tax Court · 1990

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API