Bennett v. Commissioner
United States Board of Tax Appeals
Petitioner J. M. Bennett, without consideration, delivered by endorsement certain notes to a trust created by him for the benefit of his children. The notes in question later became worthless. On the assumption that he was personally liable by reason of his endorsement, he substituted in lieu thereof securities having a cost basis in excess of the face amount of the notes taken up.
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Petitioner J. M. Bennett, without consideration, delivered by endorsement certain notes to a trust created by him for the benefit of his children. The notes in question later became worthless. On the assumption that he was personally liable by reason of his endorsement, he substituted in lieu thereof securities having a cost basis in excess of the face amount of the notes taken up. Held, as the trust was not a holder for value and there was no consideration for the endorsement, the worthless notes did not give rise to a bad debt deduction by petitioner; held, further, petitioners are not…
1Opinion of the Court
JAMIE A. BENNETT, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
J. M. BENNETT, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Bennett v. Commissioner
Docket Nos. 94439, 94440.
United States Board of Tax Appeals
40 B.T.A. 745; 1939 BTA LEXIS 813;
October 18, 1939, Promulgated
Petitioner J. M. Bennett, without consideration, delivered by endorsement certain notes to a trust created by him for the benefit of his children. The notes in question later became worthless. On the assumption that he was personally liable by reason of his endorsement, he substituted in lieu thereof…
2Cases cited1 opinion
- Bennett v. CommissionerUnited States Board of Tax Appeals · 1939