Legal Opinion

Stein v. Commissioner

United States Tax Court

Decided February 21, 1962No. Docket Nos. 69931, 69932, 70277, 78991Published

Petitioner's decedent received the residue of his deceased wife's estate, and also received payments from a controlled corporation.

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Petitioner's decedent received the residue of his deceased wife's estate, and also received payments from a controlled corporation. In prior cases the payments from the corporation to petitioner's decedent and his wife which were not reported as income either by them or by the corporation were determined to be taxable income to the corporation and corporate distributions taxable to the recipients, and additions to tax for fraud were imposed upon all three petitioners therein. The deficiencies and additions thereto assessed against the wife and the corporation remain unpaid in whole or in…

1Opinion of the Court

Estate of Samuel Stein, Deceased, Lazarus I. Levine and Norman L. Marks, Executors, as Alleged Transferee of Estate of Esther M. Stein, Deceased, as Alleged Transferee of National Thread Co., Inc., Transferor, et al., 1 Petitioners, v. Commissioner of Internal Revenue, Respondent

Stein v. Commissioner

Docket Nos. 69931, 69932, 70277, 78991

United States Tax Court

37 T.C. 945; 1962 U.S. Tax Ct. LEXIS 188;

February 21, 1962, Filed

Decisions will be entered under Rule 50.

Petitioner's decedent received the residue of his deceased wife's estate, and also received payments from a controlled corporation.…

2Cases cited37 opinions

  1. North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
  2. Flora v. United StatesSupreme Court of the United States · 1960
  3. Commissioner v. SternSupreme Court of the United States · 1958
  4. Commissioner v. Gooch Milling & Elevator Co.Supreme Court of the United States · 1944
  5. Healy v. CommissionerSupreme Court of the United States · 1953

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