Legal Opinion
Estate of DeNiro v. Commissioner
Court of Appeals for the Sixth Circuit
Decided July 18, 1986No. 85-1483PublishedCited by 6 opinions
1Opinion of the Court
BOGGS, Circuit Judge.
This is an appeal from a Tax Court decision upholding a federal income tax assessment by the Commissioner of Internal Revenue against the Estate of Vincent DeNiro. For the reasons set forth below, we reverse and remand.
I
In 1969, the Estate of Vincent DeNiro received from National Cigarette Sales (NCS), a corporation formerly controlled by Mr. DeNiro, $89,257 with which to pay estate taxes. The Commissioner assessed *584the Estate for taxes due on the income represented by the payment, and the Estate contested the assessment before the Tax Court.
The issue before the Tax Court…
2Cases cited5 opinions
- Walter Demkowicz and Dorothy Demkowicz v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1977
- Lovell and Hart, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1972
- Commissioner v. SmithCourt of Appeals for the Fifth Circuit · 1960
- Loesch & Green Const. Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1954
- Estate of DeNiro v. CommissionerCourt of Appeals for the Sixth Circuit · 1984
3Cited by6 opinions
- Frank C. Davis, Jr. And Frank C. Davis, Jr., of the Estate of Grace K. Davis v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1989
- ESTATE OFCourt of Appeals for the Sixth Circuit · 1986
- Edward Ginsberg and Rosalie Ginsberg v. Commissioner of the Internal Revenue ServiceCourt of Appeals for the Sixth Circuit · 1993
- Estate of Deniro v. Comm'rUnited States Tax Court · 1990
- Goodman v. CommissionerUnited States Tax Court · 1990
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