Legal Opinion

Markle v. Commissioner

United States Tax Court

Decided March 26, 1952No. Docket No. 22060Published

1. Deductions. -- Held, petitioner did not sustain his burden of proving distributions or advances to wholly owned corporation to enable it to pay certain indebtednesses and real estate taxes were allowable as business bad debts or losses incurred in transactions entered into for profit.

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1. Deductions. -- Held, petitioner did not sustain his burden of proving distributions or advances to wholly owned corporation to enable it to pay certain indebtednesses and real estate taxes were allowable as business bad debts or losses incurred in transactions entered into for profit. Held, further, respondent did not sustain burden of proving affirmative allegation that advances were contributions to capital. 2. Basis. -- Held, on the facts, basis of petitioner's interest in trust was original amount of investment therein.

1Opinion of the Court

George B. Markle, Jr., and Gertrude N. Markle, Petitioners, v. Commissioner of Internal Revenue, Respondent

Markle v. Commissioner

Docket No. 22060

United States Tax Court

17 T.C. 1593; 1952 U.S. Tax Ct. LEXIS 236;

March 26, 1952, Promulgated

Decision will be entered under Rule 50.

1. Deductions. -- Held, petitioner did not sustain his burden of proving distributions or advances to wholly owned corporation to enable it to pay certain indebtednesses and real estate taxes were allowable as business bad debts or losses incurred in transactions entered into for profit. Held, further, respondent did not…

2Cases cited19 opinions

  1. Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
  2. Burnet v. ClarkSupreme Court of the United States · 1932
  3. Helvering v. ReynoldsSupreme Court of the United States · 1941
  4. Maguire v. CommissionerSupreme Court of the United States · 1941
  5. Boissevain v. CommissionerUnited States Tax Court · 1951

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