Ach v. Commissioner
United States Tax Court
1. Held: The Commissioner was warranted in allocating income of corporate petitioner to individual petitioner under section 482, I.R.C. 1954. Allocation approved as revised herein. 2. Held, individual petitioner acquired control of corporate petitioner for purpose of avoiding tax within meaning of section 269, I.R.C. 1954, and section 129, I.R.C. 1939.
1Opinion of the Court
Pauline W. Ach, et al., 1 Petitioners, v. Commissioner of Internal Revenue, Respondent
Ach v. Commissioner
Docket Nos. 94162, 94163, 94164
United States Tax Court
42 T.C. 114; 1964 U.S. Tax Ct. LEXIS 117;
April 15, 1964, Filed
Decisions will be entered under Rule 50.
1. Held: The Commissioner was warranted in allocating income of corporate petitioner to individual petitioner under section 482, I.R.C. 1954. Allocation approved as revised herein.
2. Held, individual petitioner acquired control of corporate petitioner for purpose of avoiding tax within meaning of section 269, I.R.C. 1954, and section…
2Cases cited24 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Libson Shops, Inc., v. Koehler, District Director of Internal RevenueSupreme Court of the United States · 1957
- Grenada Industries, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1953
- Ach v. CommissionerUnited States Tax Court · 1964
- National Securities Corp. v. Com'r of Internal RevenueCourt of Appeals for the Third Circuit · 1943
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