Legal Opinion

Constantin v. Commissioner

United States Tax Court

Decided January 31, 1966No. Docket No. 95445UnpublishedCited by 2 opinions

Petitioner, an independent oil producer, made substantial advances of funds on behalf of his brother, Jules, who was his manager of production, to pay for Jules' share in acquiring, developing or operating certain oil and gas leases.

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Petitioner, an independent oil producer, made substantial advances of funds on behalf of his brother, Jules, who was his manager of production, to pay for Jules' share in acquiring, developing or operating certain oil and gas leases. Such advances were made to Jules on an open account for over a period of about ten years prior to Jules' death in 1953. No notes or other evidence of indebtedness were signed by Jules; there was no provision for interest or collateral; and no definite understanding as to the method or time for repayment. In 1958 the executors for the estate of Jules finally…

1Opinion of the Court

E. Constantin, Jr. and Ruth F. Constantin v. Commissioner.

Constantin v. Commissioner

Docket No. 95445.

United States Tax Court

T.C. Memo 1966-27; 1966 Tax Ct. Memo LEXIS 254; 25 T.C.M. (CCH) 166; T.C.M. (RIA) 66027;

January 31, 1966

Petitioner, an independent oil producer, made substantial advances of funds on behalf of his brother, Jules, who was his manager of production, to pay for Jules' share in acquiring, developing or operating certain oil and gas leases. Such advances were made to Jules on an open account for over a period of about ten years prior to Jules' death in 1953. No notes or other…

2Cases cited30 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Doyle v. Mitchell Brothers Co.Supreme Court of the United States · 1918
  3. Clark v. CommissionerUnited States Tax Court · 1952
  4. Gulf Pipe Line Co. v. NearenTexas Commission of Appeals · 1940
  5. Denver & Rio Grande Western Railroad Company v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1960

25 more not listed; retrieve them via the Exa API.

3Cited by2 opinions

  1. Holderness v. CommissionerUnited States Tax Court · 1977
  2. SCHMIT v. COMMISSIONERUnited States Tax Court · 1982

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