Legal Opinion

Greenspon v. Commissioner

United States Tax Court

Decided February 27, 1947No. Docket Nos. 8684, 9206Published

Prior to 1931 petitioners owned all the stock of a corporation and were the managing officers. They orally guaranteed loans made to the corporation by their brother-in-law and by another company in the period from 1928 to 1931. In 1931 receivership proceedings were instituted against the corporation, and it was finally liquidated in 1938. The creditors of the corporation received no payments from the receiver on account of their claims.

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Prior to 1931 petitioners owned all the stock of a corporation and were the managing officers. They orally guaranteed loans made to the corporation by their brother-in-law and by another company in the period from 1928 to 1931. In 1931 receivership proceedings were instituted against the corporation, and it was finally liquidated in 1938. The creditors of the corporation received no payments from the receiver on account of their claims. One of the petitioners was also adjudged a bankrupt in 1938. Meanwhile, in 1932 petitioners organized a new corporation with money advanced by their…

1Opinion of the Court

Abraham Greenspon, Petitioner, v. Commissioner of Internal Revenue, Respondent. Louis Greenspon, Petitioner, v. Commissioner of Internal Revenue, Respondent

Greenspon v. Commissioner

Docket Nos. 8684, 9206

United States Tax Court

8 T.C. 431; 1947 U.S. Tax Ct. LEXIS 269;

February 27, 1947, Promulgated

Decisions will be entered under Rule 50.

Prior to 1931 petitioners owned all the stock of a corporation and were the managing officers. They orally guaranteed loans made to the corporation by their brother-in-law and by another company in the period from 1928 to 1931. In 1931 receivership proceedings…

2Cases cited6 opinions

  1. Zavelo v. ReevesSupreme Court of the United States · 1913
  2. Baron v. KurnSupreme Court of Missouri · 1942
  3. Ingersoll v. Commissioner (A)United States Tax Court · 1946
  4. Hess v. CommissionerUnited States Tax Court · 1946
  5. Farmers & Merchants Bank v. RichardsMissouri Court of Appeals · 1906

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