Hood v. Commissioner
United States Tax Court
H operated a sole proprietorship, and later incorporated HIF, which assumed the business of the sole proprietorship. H was sole shareholder and president, and indispensable to the success, of HIF. After HIF was incorporated, H was indicted and tried for criminal tax evasion and false declaration arising from the alleged failure to report income from the sole proprietorship. HIF paid legal fees for H's defense of the criminal charges.
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H operated a sole proprietorship, and later incorporated HIF, which assumed the business of the sole proprietorship. H was sole shareholder and president, and indispensable to the success, of HIF. After HIF was incorporated, H was indicted and tried for criminal tax evasion and false declaration arising from the alleged failure to report income from the sole proprietorship. HIF paid legal fees for H's defense of the criminal charges. HELD, the facts of the instant cases are not materially distinguishable from the facts of Jack's Maintenance Contractors, Inc. v. Commissioner, T.C. Memo…
1Opinion of the Court
Gale, Judge:
These cases were consolidated for trial, briefing, and opinion. Respondent determined the following deficiencies and accuracy-related penalties for petitioners Lenward C. and Barbara P. Hood’s 1991 (calendar) taxable year and for petitioner Hood’s Institutional Foods, Inc.’s taxable year ended June 30, 1991:
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Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.
After concessions,1 the remaining issues for decision are: (1)…
2Cases cited21 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- United States v. GilmoreSupreme Court of the United States · 1963
- Electric & Neon, Inc. v. CommissionerUnited States Tax Court · 1971
16 more not listed; retrieve them via the Exa API.
3Cited by37 opinions
- Capital Video Corp. v. CommissionerCourt of Appeals for the First Circuit · 2002
- Hubert Enters. v. Comm'rUnited States Tax Court · 2005
- Square D Co. v. Comm'rUnited States Tax Court · 2003
- HAN v. COMMISSIONERUnited States Tax Court · 2002
- Welle v. CommissionerUnited States Tax Court · 2013
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