Ach v. Commissioner
United States Tax Court
1. Held: The Commissioner was warranted in allocating income of corporate petitioner to individual petitioner under section 482, I.R.C. 1954. Allocation approved as revised herein. 2. Held, individual petitioner acquired control of corporate petitioner for purpose of avoiding tax within meaning of section 269, I.R.C. 1954, and section 129, I.R.C. 1939.
1Opinion of the Court
OPINION
Raum, Judge:
1. Taxability of Vogues and Vanities Profits to Petitioner Pauline W. Aoh. — During the years 1954^58, profits in the amounts of $36,569.24, $40,663.64, $44,538.90, $41,777.51, and $45,297.28, respectively, were realized from Pauline’s operation of the dress business known as Vogues and Vanities in Cincinnati, Ohio. These amounts were reflected in the returns for these years filed by the Ach Corp., but no taxes were paid thereon by reason of net operating loss carryovers from earlier years when Roger conducted a dairy business in Rising Sun, Ind., under the same…
2Cases cited23 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Libson Shops, Inc., v. Koehler, District Director of Internal RevenueSupreme Court of the United States · 1957
- Grenada Industries, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1953
- National Securities Corp. v. Com'r of Internal RevenueCourt of Appeals for the Third Circuit · 1943
- Ballentine Motor Co., Inc., Ballentine's, and Ballentine Motors, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1963
18 more not listed; retrieve them via the Exa API.
3Cited by122 opinions
- Achiro v. CommissionerUnited States Tax Court · 1981
- Nat Harrison Assoc., Inc. v. CommissionerUnited States Tax Court · 1964
- Foster v. Comm'rUnited States Tax Court · 1983
- Rubin v. CommissionerUnited States Tax Court · 1971
- Haag v. CommissionerUnited States Tax Court · 1987
117 more not listed; retrieve them via the Exa API.