Investment Research Associates - Page 199




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         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).                                         








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