Graf v. Commissioner
United States Tax Court
Petitioner Mohammad Shafi a cash basis taxpayer, is a doctor practicing medicine in Wisconsin. In 1977, petitioner entered into a tax shelter promoted by the International Monetary Exchange (IME), a Panamanian corporation, wherein he purported to provide dredging services in Panama. Petitioner paid $ 40,000 to a local subcontractor to do the actual work. IME allegedly advanced $ 30,000 on behalf of petitioner to the subcontractor.
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Petitioner Mohammad Shafi a cash basis taxpayer, is a doctor practicing medicine in Wisconsin. In 1977, petitioner entered into a tax shelter promoted by the International Monetary Exchange (IME), a Panamanian corporation, wherein he purported to provide dredging services in Panama. Petitioner paid $ 40,000 to a local subcontractor to do the actual work. IME allegedly advanced $ 30,000 on behalf of petitioner to the subcontractor. Thus, petitioner paid $ 10,000 in cash and issued a $ 30,000 promissory note to IME. The note was payable only out of profits from the sale of oceanfront lots…
1Opinion of the Court
OPINION
Fay, Judge:
Respondent determined the following deficiencies in petitioners’ 1977 Federal income tax:
Docket No. Deficiency
7888-80 $33,841.00
9149-80 20,771.22
These cases are consolidated for purposes of trial, briefing, and opinion. Petitioners in docket No. 9149-80 are presently before the Court on respondent’s motion for partial summary judgment under Rule 121.1 The only issue raised by respondent’s motion is whether a deduction is allowable with respect to a $30,000 payment by note for certain dredging services allegedly performed in Panama.
Petitioners in docket No. 9149-80, Mohammad…
2Cases cited37 opinions
- Adickes v. S. H. Kress & Co.Supreme Court of the United States · 1970
- Crane v. CommissionerSupreme Court of the United States · 1947
- Jacklin v. CommissionerUnited States Tax Court · 1982
- Estate of Charles T. Franklin, Deceased v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1976
- Eckert v. BurnetSupreme Court of the United States · 1931
32 more not listed; retrieve them via the Exa API.
3Cited by54 opinions
- Naftel v. CommissionerUnited States Tax Court · 1985
- Fox v. CommissionerUnited States Tax Court · 1983
- Estate of Baron v. CommissionerUnited States Tax Court · 1984
- Waddell v. CommissionerUnited States Tax Court · 1986
- Jackson v. CommissionerUnited States Tax Court · 1986
49 more not listed; retrieve them via the Exa API.