Legal Opinion

Linder v. Commissioner

United States Tax Court

Decided August 30, 1977No. Docket No. 294-75Published

Petitioner, a New Jersey resident, executed gratuitous promises under seal to pay certain sums to his sister. He paid and deducted interest on the promised amounts. Held, under New Jersey law the sealed promises are unenforceable and interest paid with respect thereto is nondeductible.

1Opinion of the Court

Joseph Linder, Petitioner v. Commissioner of Internal Revenue, Respondent

Linder v. Commissioner

Docket No. 294-75

United States Tax Court

68 T.C. 792; 1977 U.S. Tax Ct. LEXIS 57;

August 30, 1977, Filed

Decision will be entered for the respondent.

Petitioner, a New Jersey resident, executed gratuitous promises under seal to pay certain sums to his sister. He paid and deducted interest on the promised amounts. Held, under New Jersey law the sealed promises are unenforceable and interest paid with respect thereto is nondeductible.

Joseph Linder, pro se.

Marwin A. Batt, for the respondent.

Hall, Judge.

HALL

2Cases cited31 opinions

  1. Commissioner v. Estate of BoschSupreme Court of the United States · 1967
  2. Carl E. Weller and Emily I. Weller v. Commissioner of Internal Revenue, W. Stuart Emmons v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1959
  3. Morton v. CommissionerUnited States Board of Tax Appeals · 1938
  4. Morton v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1940
  5. Autenreith v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1940

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