Pascarelli v. Commissioner
United States Tax Court
During the years in issue, the petitioner and D lived together as man and wife, although they were not married. D transferred substantial funds directly to the petitioner, transferred other funds into a brokerage account in her name, and made payments to contractors for improvements to her realty. The petitioner assisted D in entertaining his business associates and spent some of the transferred funds for D's purposes pursuant to his instructions.
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During the years in issue, the petitioner and D lived together as man and wife, although they were not married. D transferred substantial funds directly to the petitioner, transferred other funds into a brokerage account in her name, and made payments to contractors for improvements to her realty. The petitioner assisted D in entertaining his business associates and spent some of the transferred funds for D's purposes pursuant to his instructions. Held, the funds transferred directly to the petitioner and to the brokerage account in her name and the funds spent for the improvement of her…
1Opinion of the Court
Lillian Pascarelli, Petitioner v. Commissioner of Internal Revenue, respondent; Lillian Pascarelli, Transferee, Petitioner v. Commissioner of Internal Revenue, respondent
Pascarelli v. Commissioner
Docket Nos. 4587-66, 3596-68
United States Tax Court
55 T.C. 1082; 1971 U.S. Tax Ct. LEXIS 164;
March 25, 1971, Filed
Decisions will be entered under Rule 50.
During the years in issue, the petitioner and D lived together as man and wife, although they were not married. D transferred substantial funds directly to the petitioner, transferred other funds into a brokerage account in her name, and made…
2Cases cited38 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Burnet v. GuggenheimSupreme Court of the United States · 1933
- Quock Ting v. United StatesSupreme Court of the United States · 1891
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