Legal Opinion

Achiro v. Commissioner

United States Tax Court

Decided October 19, 1981No. Docket Nos. 467-79, 468-79PublishedCited by 184 opinions

Achiro and Rossi each owned 50 percent of the stock of Tahoe City Disposal, and each owned 25 percent of the stock of Kings Beach Disposal. In 1974, Achiro and Rossi incorporated A & R for the purpose of rendering management services to Tahoe City Disposal and Kings Beach Disposal. Achiro and Rossi each owned 24 percent of A & R's stock, and Renato Achiro (Achiro's brother and Rossi's brother-in-law) owned the remaining 52 percent.

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Achiro and Rossi each owned 50 percent of the stock of Tahoe City Disposal, and each owned 25 percent of the stock of Kings Beach Disposal. In 1974, Achiro and Rossi incorporated A & R for the purpose of rendering management services to Tahoe City Disposal and Kings Beach Disposal. Achiro and Rossi each owned 24 percent of A & R's stock, and Renato Achiro (Achiro's brother and Rossi's brother-in-law) owned the remaining 52 percent. A & R entered into management service agreements with Tahoe City Disposal and Kings Beach Disposal pursuant to which A & R provided those corporations with…

1Opinion of the Court

Hall, Judge:

Respondent determined deficiencies in petitioners’ income taxes as follows:

Petitioners Year Deficiency

Silvano and Carol Achiro

Docket No. 467-79. 1975 $13,414

1976 19,979

Peter and Gemma Rossi

Docket No. 468-79. 1975 13,417

1976 20,061

The issues for decision are:(1) Whether respondent properly allocated all of the income and deductions of A & R to Tahoe City Disposal and Kings Beach Disposal under:(a) Section 482;1(b) Section 269; or(c) Section 61 (sham corporation theory or assignment of income doctrine);(2) In the alternative, whether amounts paid by Tahoe City Disposal and Kings…

2Cases cited33 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Lucas v. EarlSupreme Court of the United States · 1930
  3. Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
  4. Klein v. Board of Tax Supervisors of Jefferson Cty.Supreme Court of the United States · 1930
  5. Ach v. CommissionerUnited States Tax Court · 1964

28 more not listed; retrieve them via the Exa API.

3Cited by184 opinions

  1. Shea v. CommissionerUnited States Tax Court · 1999
  2. Foster v. Comm'rUnited States Tax Court · 1983
  3. Wayne Bolt & Nut Co. v. CommissionerUnited States Tax Court · 1989
  4. Church of Scientology v. CommissionerUnited States Tax Court · 1984
  5. Sundstrand Corp. v. CommissionerUnited States Tax Court · 1991

179 more not listed; retrieve them via the Exa API.

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