Silverstein v. Commissioner
United States Tax Court
Payment of petitioner's prior years' tax liabilities by a corporation of which petitioner was an officer and stockholder constitutes taxable income to petitioner.
1Opinion of the Court
Drennen, Judge:
Respondent determined deficiencies in the joint income tax of L. L. Silverstein and Rose L. Silverstein for 1955 and 1956 in the amounts of $2,632.61 and $2,575.22, respectively. The only issue is whether payments of $10,000 made by a corporation of which L. L. Silverstein was a one-third owner on prior years’ tax liabilities of L. L. Silverstein are taxable to L. L. Silverstein as constructive dividends.
FINDINGS OF FACT.
The stipulated facts are so found.
L. L. Silverstein and Rose L. Silverstein were husband and wife during the year 1955 and filed a joint Federal income tax…
2Cases cited9 opinions
- Old Colony Trust Co. v. CommissionerSupreme Court of the United States · 1929
- Wall v. United StatesCourt of Appeals for the Fourth Circuit · 1947
- Irving Sachs v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1960
- Paramount-Richards Theatres, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1946
- Sachs v. CommissionerUnited States Tax Court · 1959
4 more not listed; retrieve them via the Exa API.
3Cited by13 opinions
- Yelencsics v. CommissionerUnited States Tax Court · 1980
- Estate of De Niro v. CommissionerUnited States Tax Court · 1982
- Amis v. CommissionerUnited States Tax Court · 1984
- Schnallinger v. CommissionerUnited States Tax Court · 1987
- Sparks Nugget, Inc. v. CommissionerUnited States Tax Court · 1970
8 more not listed; retrieve them via the Exa API.