Sellers v. Commissioner
United States Tax Court
1. The Commissioner determined that Frank E. Sellers and Norpaco Builders, Inc., were the principals in several real estate sales during 1965 and 1966 and that Frank E. Sellers is liable as a transferee for any taxes owed by Norpaco for those years. Frank E. Sellers was the president and sole stockholder of Norpaco. The corporation maintained no separate books and records, and its financial transactions were conducted through Frank E. Sellers' bank account.
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1. The Commissioner determined that Frank E. Sellers and Norpaco Builders, Inc., were the principals in several real estate sales during 1965 and 1966 and that Frank E. Sellers is liable as a transferee for any taxes owed by Norpaco for those years. Frank E. Sellers was the president and sole stockholder of Norpaco. The corporation maintained no separate books and records, and its financial transactions were conducted through Frank E. Sellers' bank account. Held, the taxpayers failed to establish that they were acting only as agents or nominees for another in their connection with the…
1Opinion of the Court
FRANK E. SELLERS and POLLY M. SELLERS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent.
FRANK E. SELLERS, TRANSFEREE OF ASSETS OF NORPACO BUILDERS, INC., TRANSFEROR, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent.
NORPACO BUILDERS, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent.
Sellers v. Commissioner
Docket Nos. 1504-74 1505-74 4530-74
United States Tax Court
T.C. Memo 1977-70; 1977 Tax Ct. Memo LEXIS 368; 36 T.C.M. (CCH) 305; T.C.M. (RIA) 770070;
March 21, 1977, Filed
1. The Commissioner determined that Frank E. Sellers and Norpaco Builders, Inc., were the…
2Cases cited50 opinions
- Crane v. CommissionerSupreme Court of the United States · 1947
- Commissioner v. SternSupreme Court of the United States · 1958
- Halle v. CommissionerUnited States Tax Court · 1946
- Halle v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1949
- Pritchett v. CommissionerUnited States Tax Court · 1974
45 more not listed; retrieve them via the Exa API.
3Cited by2 opinions
- Boynton v. CommissionerUnited States Tax Court · 1979
- Boynton v. CommissionerUnited States Tax Court · 1979