- 271 - whose names were on the various accounts did not earn the taxable amounts attributed to those accounts. A taxpayer cannot expect the Commissioner to recognize the separate identity of an entity where the taxpayer himself so blatantly ignores any separate existence. Nor should the courts require the Commissioner to do so. On the record presented to us, we find that IRA, Holding Co., their subsidiaries, including Zeus, Zion, Carlco, TMT, and BWK, Inc. did not carry on any business and were only the alter egos of Kanter, Lisle, and Ballard. We find the various entities to be pure tax avoidance vehicles. The corporations were nothing more than a few incorporating papers of no significance except when a tax return was due. Petitioners diverted millions of dollars of income. The make-believe corporations were shams and too transparent to accept for tax purposes. 2. Assignment of Income Even if the corporations that received the payments from the Five had been viable entities, that would not preclude application of the assignment of income doctrine, as a taxpayer could assign income to a corporation that conducts real and substantial business in an attempt to avoid tax. See Haag v. Commissioner, 88 T.C. 604, 611 (1987), affd. without published opinion 855 F.2d 855 (8th Cir. 1988).Page: Previous 261 262 263 264 265 266 267 268 269 270 271 272 273 274 275 276 277 278 279 280 Next
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