Jaffe v. Commissioner
United States Tax Court
Held, losses growing out of loans made by two taxpayers, stockholder-employees, to their wholly owned corporation, as well as losses from guarantees of loans by a bank to their corporation, were business bad debts, deductible in full under section 166(a), I.R.C. 1954; the loans and guarantees did not result in "nonbusiness" debts under section 166(d), since taxpayers were motivated by a purpose to protect their jobs, both of them being virtually unemployable elsewhere.
1Opinion of the Court
Isidor Jaffe and Anna Jaffe v. Commissioner. Samuel Jaffe and Bette Jaffe v. Commissioner.
Jaffe v. Commissioner
Docket Nos. 2903-66, 2904-66.
United States Tax Court
T.C. Memo 1967-215; 1967 Tax Ct. Memo LEXIS 48; 26 T.C.M. (CCH) 1063; T.C.M. (RIA) 67215;
October 30, 1967
Held, losses growing out of loans made by two taxpayers, stockholder-employees, to their wholly owned corporation, as well as losses from guarantees of loans by a bank to their corporation, were business bad debts, deductible in full under section 166(a), I.R.C. 1954; the loans and guarantees did not result in "nonbusiness" debts…
2Cases cited10 opinions
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Whipple v. CommissionerSupreme Court of the United States · 1963
- Burnet v. ClarkSupreme Court of the United States · 1932
- Dalton v. BowersSupreme Court of the United States · 1932
- Millsap v. CommissionerUnited States Tax Court · 1966
5 more not listed; retrieve them via the Exa API.
3Cited by4 opinions
- Donald C. Niblock, Jr., and Marilyn Niblock v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1969
- La Staiti v. CommissionerUnited States Tax Court · 1980
- Hirsch v. CommissionerUnited States Tax Court · 1971
- Niblock v. CommissionerUnited States Tax Court · 1968