Pascarelli v. Commissioner
United States Tax Court
During the years in issue, the petitioner and D lived together as man and wife, although they were not married. D transferred substantial funds directly to the petitioner, transferred other funds into a brokerage account in her name, and made payments to contractors for improvements to her realty. The petitioner assisted D in entertaining his business associates and spent some of the transferred funds for D's purposes pursuant to his instructions.
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During the years in issue, the petitioner and D lived together as man and wife, although they were not married. D transferred substantial funds directly to the petitioner, transferred other funds into a brokerage account in her name, and made payments to contractors for improvements to her realty. The petitioner assisted D in entertaining his business associates and spent some of the transferred funds for D's purposes pursuant to his instructions. Held, the funds transferred directly to the petitioner and to the brokerage account in her name and the funds spent for the improvement of her…
1Opinion of the Court
Simpson, Judge:
In docket No. 4587-66, the respondent determined the following deficiencies in and additions to the Federal income tax of the petitioner:
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In docket No. 8596-68, the respondent determined the following deficiencies in and additions to the Federal gift tax of Anthony DeAngelis, and asserted that the petitioner was liable for such amounts as transferee of Mr. DeAngelis’ assets:
Addition,
Year Deficiency sec. 6651(a)
1959 _$ S, 360.90 $ 840.22
1960 _ 16,101.58 4,025.39
1961_ 9,067.50 2,266.87
1962 _ 6,671.25 1,667.81
1963 [2]_ 10, 687. 50 2, 671. 87
The original deficiencies…
2Cases cited37 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Burnet v. GuggenheimSupreme Court of the United States · 1933
- Quock Ting v. United StatesSupreme Court of the United States · 1891
32 more not listed; retrieve them via the Exa API.
3Cited by20 opinions
- Green v. CommissionerUnited States Tax Court · 1987
- Estate of Cavett v. CommissionerUnited States Tax Court · 2000
- Fenstermaker v. CommissionerUnited States Tax Court · 1978
- Johnson v. CommissionerUnited States Tax Court · 1972
- Clower v. CommissionerUnited States Tax Court · 1990
15 more not listed; retrieve them via the Exa API.