Anderson v. Commissioner
United States Tax Court
P was the majority shareholder, president, and treasurer of Anderco, Inc. (A). P deposited large sums of money, which had been diverted from A, into various savings accounts held in P's name between 1976 and 1979. P withdrew most of the deposits in 1979, and, in 1981, deposited much of the withdrawn sums into certificates of deposit, some of which were held in the name of P or A. The notice of deficiency was sent to P more than 3 years after he filed his tax returns;…
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P was the majority shareholder, president, and treasurer of Anderco, Inc. (A). P deposited large sums of money, which had been diverted from A, into various savings accounts held in P's name between 1976 and 1979. P withdrew most of the deposits in 1979, and, in 1981, deposited much of the withdrawn sums into certificates of deposit, some of which were held in the name of P or A. The notice of deficiency was sent to P more than 3 years after he filed his tax returns; however, the parties stipulated that, because of extensions, the limitations period had not expired for 1977, 1980, and 1981.…
1Opinion of the Court
ROBERT R. ANDERSON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Anderson v. Commissioner
Docket No. 3004-90
United States Tax Court
T.C. Memo 1995-8; 1995 Tax Ct. Memo LEXIS 8; 69 T.C.M. (CCH) 1609; T.C.M. (RIA) 95008;
January 11, 1995, Filed
Decision will be entered under Rule 155.
P was the majority shareholder, president, and treasurer of Anderco, Inc. (A). P deposited large sums of money, which had been diverted from A, into various savings accounts held in P's name between 1976 and 1979. P withdrew most of the deposits in 1979, and, in 1981, deposited much of the withdrawn sums…
2Cases cited59 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Helvering v. CliffordSupreme Court of the United States · 1940
- Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
- Stone v. CommissionerUnited States Tax Court · 1971
- Gajewski v. CommissionerUnited States Tax Court · 1976
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