Calderazzo v. Commissioner
United States Tax Court
Held: Petitioner, Wilma Calderazzo, received liquidating distributions in 1966 in the total amount of $ 103,596.17 from two corporations in which she owned all the capital stock. Since she failed to prove her basis in the stock the entire amount of the distributions is taxable as long-term capital gain. Held, further: Wilma Calderazzo is liable for the 25-percent addition to tax under sec. 6651(a) for failure to file an income tax return for 1966.
1Opinion of the Court
JOHN CALDERAZZO and WILMA CALDERAZZO, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Calderazzo v. Commissioner
Docket Nos. 6315-71, 6316-71.
United States Tax Court
T.C. Memo 1975-1; 1975 Tax Ct. Memo LEXIS 370; 34 T.C.M. (CCH) 1; T.C.M. (RIA) 750001;
January 6, 1975, Filed.
Held: Petitioner, Wilma Calderazzo, received liquidating distributions in 1966 in the total amount of $ 103,596.17 from two corporations in which she owned all the capital stock. Since she failed to prove her basis in the stock the entire amount of the distributions is taxable as long-term capital gain. Held,…
2Cases cited6 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Bebb v. CommissionerUnited States Tax Court · 1961
- Rubber Research, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1970
- William B. Breland v. United States of America, United States of America v. William B. BrelandCourt of Appeals for the Fifth Circuit · 1963
- Frank T. Shull and Ann R. Shull v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1961
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