Legal Opinion

AJF Transp. Consultants, Inc. v. Commissioner

United States Tax Court

Decided January 28, 1999No. Nos. 12590-95, 24190-96, 24482-96, 24483-96Unpublished

J is a corporation engaged in furniture delivery services. F is J's sole shareholder and president. J's client issued checks to J for its delivery services and for fuel costs. F cashed the checks personally and diverted the funds for his own personal benefit. None of the diverted funds were reported as income on F's individual tax returns or on J's corporate tax returns for the 1988, 1989, and 1990 taxable years.

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J is a corporation engaged in furniture delivery services. F is J's sole shareholder and president. J's client issued checks to J for its delivery services and for fuel costs. F cashed the checks personally and diverted the funds for his own personal benefit. None of the diverted funds were reported as income on F's individual tax returns or on J's corporate tax returns for the 1988, 1989, and 1990 taxable years. J did not timely file its corporate tax returns for the years at issue. R determined that the full amount of the diverted funds was taxable to both J and F. R's deficiency notices…

1Opinion of the Court

AJF TRANSPORATION CONSULTANTS, INC., ET AL., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

AJF Transp. Consultants, Inc. v. Commissioner

Nos. 12590-95, 24190-96, 24482-96, 24483-96

United States Tax Court

T.C. Memo 1999-16; 1999 Tax Ct. Memo LEXIS 17; 77 T.C.M. (CCH) 1244; T.C.M. (RIA) 99016;

January 28, 1999, Filed

Decisions will be entered under Rule 155.

J is a corporation engaged in furniture delivery services. F is J's sole shareholder and president. J's client issued checks to J for its delivery services and for fuel costs. F cashed the checks personally and diverted the funds…

2Cases cited47 opinions

  1. Spies v. United StatesSupreme Court of the United States · 1943
  2. United States v. BoyleSupreme Court of the United States · 1985
  3. Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
  4. Corliss v. BowersSupreme Court of the United States · 1930
  5. Rowlee v. CommissionerUnited States Tax Court · 1983

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