Kaufman

Petitioner, Albert A. Kaufman, a resident of California, seeks reversal of a decision of the Board of Tax Appeals redetermining a claimed deficiency in respect of his income tax for 1936.

On May 6, 1923, petitioner organized a California corporation called Albert A. Kaufman Investment Company having an authorized capital of 1,000 shares, all of which, except three qualifying shares, were issued to petitioner. All the shares were issued without consideration. The corporation never transacted any business. Petitioner, however, in transacting his business, sometimes used the corporation’s name instead of his own. Thus, on occasion, the corporation served as a mask to conceal petitioner’s identity. That appears to have been its sole function.

On May 8, 1929, petitioner and Rodeo Land & Water Company, a California corporation (hereafter called Rodeo), made a contract whereby Rodeo agreed to sell and petitioner agreed to buy Lot 3 of Tract 7954 in Beverly Hills, California, for $25,000, payable in instalments. The contract was evidenced by two written instruments. Both were executed by petitioner. In one petitioner called himself by his right name. In the other he used his corporate…