Williams v. Comm'r
United States Tax Court
In 1993 P established a British Virgin Islands (BVI) corporation, A, and placed the shares in a BVI trust of which he was the sole beneficiary. P opened accounts in the name of A with a bank in Switzerland. P provided consulting, negotiation, and other services to companies and governments, and his clients transferred money into A's accounts to pay for those services. P did not report any of this income on any U.S.
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In 1993 P established a British Virgin Islands (BVI) corporation, A, and placed the shares in a BVI trust of which he was the sole beneficiary. P opened accounts in the name of A with a bank in Switzerland. P provided consulting, negotiation, and other services to companies and governments, and his clients transferred money into A's accounts to pay for those services. P did not report any of this income on any U.S. Federal income tax return for 1993 through 2000, except that in 2003 he amended his 1999 and 2000 individual income tax returns to report investment income earned on the amounts in…
1Opinion of the Court
JOSEPH B. WILLIAMS, III, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Williams v. Comm'r
Docket No. 2202-08
United States Tax Court
T.C. Memo 2011-89; 2011 Tax Ct. Memo LEXIS 87; 101 T.C.M. (CCH) 1408;
April 21, 2011, Filed
Williams v. Comm'r, T.C. Memo 2009-81, 2009 Tax Ct. Memo LEXIS 79 (T.C., 2009)
An appropriate order and decision will be entered.
In 1993 P established a British Virgin Islands (BVI) corporation, A, and placed the shares in a BVI trust of which he was the sole beneficiary. P opened accounts in the name of A with a bank in Switzerland. P provided consulting,…
2Cases cited20 opinions
- Lucas v. EarlSupreme Court of the United States · 1930
- Freytag v. CommissionerSupreme Court of the United States · 1991
- HIGBEE v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001
- Indopco, Inc. v. CommissionerSupreme Court of the United States · 1992
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
15 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Philpott v. Comm'rUnited States Tax Court · 2012