Yale Ave. Corp. v. Commissioner
United States Tax Court
In 1962 petitioners entered into stipulated decisions as to certain tax liabilities which amounts, together with accrued interest, they compromised and discharged by payments of lesser amounts in 1967. The parties agree that the differences were receipts of "discharges of indebtedness" to each petitioner.
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In 1962 petitioners entered into stipulated decisions as to certain tax liabilities which amounts, together with accrued interest, they compromised and discharged by payments of lesser amounts in 1967. The parties agree that the differences were receipts of "discharges of indebtedness" to each petitioner. Held, petitioners have failed to prove that claimed contributions to capital were in fact debt obligations owing by them and consequently respondent's determinations that petitioners were solvent at the time of such discharges and therefore income was realized is approved. Held, further,…
1Opinion of the Court
FORRESTER, Judge:
For their, taxable years ended July, 31, 1967, respondent has determined deficiencies in petitioners’ income taxes of $7,312.65 in docket ISTo. 7500-70 and $2,206.98 in docket filo. 7501-7Q. He has also determined additions to those taxes under section 6651 (a) 1 in the amounts of $1,828.16 in docket No.' 7500^70 and $551.74 in docket No. 7501-70. The issues for our decision are whether petitioners realized income from certain discharges of their indebtedness and whether petitioners’ failure to file timely income tax returns was due to reasonable cause and not due to willful…
2Cases cited18 opinions
- John Kelley Co. v. CommissionerSupreme Court of the United States · 1946
- Benjamin D. And Madeline Prentice Gilbert v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1957
- Schnitzer v. CommissionerUnited States Tax Court · 1949
- Dobkin v. CommissionerUnited States Tax Court · 1950
- Benjamin D. And Madeline Prentice Gilbert, on Review v. Commissioner of Internal Revenue, on ReviewCourt of Appeals for the Second Circuit · 1959
13 more not listed; retrieve them via the Exa API.
3Cited by22 opinions
- Estate of La Meres v. Comm'rUnited States Tax Court · 1992
- Brutsche v. CommissionerUnited States Tax Court · 1976
- Thompson v. CommissionerUnited States Tax Court · 1980
- Gilboy v. CommissionerUnited States Tax Court · 1978
- Babin v. CommissionerUnited States Tax Court · 1992
17 more not listed; retrieve them via the Exa API.