Midwest Stainless, Inc. v. Commissioner
United States Tax Court
After L incorporated his cash method sole proprietorship, he received payments for its jobs in progress and paid the associated expenses. In accordance with the advice of L's accountant, the receipts and payments were treated as those of the corporation for book and tax purposes, and the corporation made a book entry on its accounting records showing a receivable from L to the corporation in the amount of the receipts, which, the parties agree, was valid debt.
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After L incorporated his cash method sole proprietorship, he received payments for its jobs in progress and paid the associated expenses. In accordance with the advice of L's accountant, the receipts and payments were treated as those of the corporation for book and tax purposes, and the corporation made a book entry on its accounting records showing a receivable from L to the corporation in the amount of the receipts, which, the parties agree, was valid debt. Thereafter, L was indicted for failing to report income of the sole proprietorship on his pre-incorporation personal income tax…
1Opinion of the Court
MIDWEST STAINLESS, INC. AND ROBERT A. AND MARY J. LECHNER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Midwest Stainless, Inc. v. Commissioner
No. 24616-97
United States Tax Court
T.C. Memo 2000-314; 2000 Tax Ct. Memo LEXIS 370; 80 T.C.M. (CCH) 472; T.C.M. (RIA) 54074;
October 4, 2000, Filed
Decision will be entered under Rule 155.
After L incorporated his cash method sole proprietorship,
he received payments for its jobs in progress and paid the
associated expenses. In accordance with the advice of L's
accountant, the receipts and payments were treated as those of
the corporation for…
2Cases cited19 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Edwards v. Cuba RailroadSupreme Court of the United States · 1925
- Haber v. CommissionerUnited States Tax Court · 1969
- Jack Haber and Doris Haber v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1970
- Magnon v. CommissionerUnited States Tax Court · 1980
14 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Barry M. Smith & Rochelle Smith v. CommissionerUnited States Tax Court · 2018