Achiro v. Commissioner
United States Tax Court
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…
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