ROUGERON

v.

ROUGERON

Citator

Cited By (31 total)

• United States v. Moore, 613 F.2d 1029 (D.C. Cir. 1979)
  …08 U.S. 625, 60 S.Ct. 380, 84 L.Ed. 521 (1940); Durovic v. Richardson, 479 F. 2d 242, 250 n.6 (7th Cir.), cert. denied, 414 U.S. 944, 94 S.Ct. 232, 38 L.Ed.2d 168 (1973); United States v. Allan Drug Co., 357 F. 2d 713, 718 (10th Cir.), cert. denied, 385 U.S. 899, 87 S.Ct. 203, 17 L.Ed.2d 131 (1966). . United States v. Scharton, supra note 128, 285 U.S. at 521-522, 52 S.Ct. at 417, 76 L.Ed. at 919; Thompson v. United States, 258 F. 196, 200-201 (8th Cir.), cert. denied, 251 U.S. 553, 40 S.Ct. 57, 64 L.Ed. 4…
• B. Forman Co., Inc. v. Commissioner OF Internal Revenue, 453 F.2d 1144 (2d Cir. 1972)
  …stock, holding that Hall, in fact, actively controlled the corporation, despite his contention that he had transferred ownership of the stock. The Tax Court, in Ach v. Commissioner, 42 T.C. 114 (1964), aff’d, 358 F. 2d 342 (6th Cir.), cert, denied, 385 U.S. 899, 87 S. Ct. 205, 17 L.Ed.2d 131 (1966), restated its view that it is not the record ownership of stock which determines control; that control is to be determined by ascertaining who, in fact, has control. In Grenada Industries, Inc. v. Commissioner,…
• Borge v. Commissioner OF Internal Revenue, 405 F.2d 673 (2d Cir. 1968)
  …y a general code provision. We thus conclude that the Tax Court was correct in upholding the Commissioner’s ruling that Borge controlled two separate businesses. See Pauline W. Ach, 42 T.C. 114 (1964), aff’d, 358 F. 2d 342 (6th Cir.), cert. denied, 385 U.S. 899, 87 S.Ct. 205, 17 L.Ed.2d 131 (1966). The Commissioner’s action in allocating a part of Danica’s income to Borge was based upon his conclusion that such allocation was necessary in order clearly to reflect the income of the two businesses under Bor…