Betts v. Commissioner
United States Tax Court
Electronics, a limited partnership, acquired at face value a $ 200,000 note of Gibraltar, in addition to stock and warrants. Electronics also furnished, for compensation, limited consulting services to Gibraltar. Gibraltar eventually became insolvent, and Electronics sold its shares of Gibraltar stock to Acme, which also guaranteed payment of the note.
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Electronics, a limited partnership, acquired at face value a $ 200,000 note of Gibraltar, in addition to stock and warrants. Electronics also furnished, for compensation, limited consulting services to Gibraltar. Gibraltar eventually became insolvent, and Electronics sold its shares of Gibraltar stock to Acme, which also guaranteed payment of the note. In 1966, Gibraltar and Acme went into receivership, and no amount was received by Electronics on the note or on the guaranty. Held, the debt of Gibraltar was not created or acquired in connection with a trade or business of Electronics. Held,…
1Opinion of the Court
David H. Betts and Joan O. Betts, Petitioners v. Commissioner of Internal Revenue, Respondent
Betts v. Commissioner
Docket No. 698-72
United States Tax Court
62 T.C. 536; 1974 U.S. Tax Ct. LEXIS 72; 62 T.C. No. 60;
July 29, 1974, Filed
Decision will be entered for the respondent.
Electronics, a limited partnership, acquired at face value a $ 200,000 note of Gibraltar, in addition to stock and warrants. Electronics also furnished, for compensation, limited consulting services to Gibraltar. Gibraltar eventually became insolvent, and Electronics sold its shares of Gibraltar stock to Acme, which also…
2Cases cited13 opinions
- Spring City Foundry Co. v. CommissionerSupreme Court of the United States · 1934
- Whipple v. CommissionerSupreme Court of the United States · 1963
- Millsap v. CommissionerUnited States Tax Court · 1966
- I. Hal Millsap, Jr., and Frances Millsap v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1968
- Imel v. CommissionerUnited States Tax Court · 1973
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