Legal Opinion
Dante and Sandi Perano v. Commissioner
United States Tax Court
Decided May 7, 2008No. 5543-06Unknown
1Opinion of the Court
130 T.C. No. 8
UNITED STATES TAX COURT DANTE AND SANDI PERANO, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 5543-06. Filed May 7, 2008. In 1994 and 1996, Ps, the sole shareholders of AG, a controlled foreign corporation as defined in sec. 957, I.R.C., transferred to AG United States real property and notes secured by such property in exchange for private annuity agreements that provided for the future payment of monthly annuities to Ps for their remaining joint lives. For 1994-2001, AG accrued liabilities with respect to those agreements in amounts that, for 2001,…
2Cases cited10 opinions
- Helvering v. Le GierseSupreme Court of the United States · 1941
- Amerco v. CommissionerUnited States Tax Court · 1991
- Amerco, Inc. Republic Insurance v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1992
- Dean v. Commissioner of Interna RevenueCourt of Appeals for the Third Circuit · 1951
- Patty v. HelveringCourt of Appeals for the Second Circuit · 1938
5 more not listed; retrieve them via the Exa API.