Koufman v. Commissioner
United States Tax Court
(1) Held, the Commissioner has the burden of proof with respect to 1963, and he has failed to prove--(a) that P was the owner of certain rental income which he received during such year for Northeast, a corporation owned by him; (b) that P realized a taxable gain when he transferred to Northeast the legal title to certain property; (c) that when Northeast transferred certain funds to P and to other corporations owned or controlled by him, it made distributions which were…
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(1) Held, the Commissioner has the burden of proof with respect to 1963, and he has failed to prove--(a) that P was the owner of certain rental income which he received during such year for Northeast, a corporation owned by him; (b) that P realized a taxable gain when he transferred to Northeast the legal title to certain property; (c) that when Northeast transferred certain funds to P and to other corporations owned or controlled by him, it made distributions which were taxable under sec. 341, I.R.C. 1954, relating to collapsible corporations; or (d) that P admitted receiving during such…
1Opinion of the Court
MANUEL M. KOUFMAN and CHARLOTTE KOUFMAN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Koufman v. Commissioner
Docket Nos. 8641-72, 8770-73.
United States Tax Court
T.C. Memo 1976-330; 1976 Tax Ct. Memo LEXIS 73; 35 T.C.M. (CCH) 1509; T.C.M. (RIA) 760330;
October 28, 1976, Filed(1) Held, the Commissioner has the burden of proof with respect to 1963, and he has failed to prove--(a) that P was the owner of certain rental income which he received during such year for Northeast, a corporation owned by him; (b) that P realized a taxable gain when he transferred to Northeast the legal…
2Cases cited41 opinions
- Stone v. CommissionerUnited States Tax Court · 1971
- Electric & Neon, Inc. v. CommissionerUnited States Tax Court · 1971
- Sonnenborn v. CommissionerUnited States Tax Court · 1971
- Mysse v. CommissionerUnited States Tax Court · 1972
- Rushing v. CommissionerUnited States Tax Court · 1969
36 more not listed; retrieve them via the Exa API.
3Cited by2 opinions
- Ralph D. Crowley and Frances A. Crowley v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1992
- Koufman v. New England Merchants National BankMassachusetts Appeals Court · 1980