Puelicher v. Commissioner
United States Tax Court
In return for services rendered, petitioner's husband received notes executed by a corporation in receivership, as maker, and members of a bondholders' protective committee, as endorsers. The notes not being paid, he filed suit thereon against the members of the committee, the corporation having been dissolved, and his administrator recovered judgment. This judgment was distributed to petitioner as sole beneficiary of her husband's estate.
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In return for services rendered, petitioner's husband received notes executed by a corporation in receivership, as maker, and members of a bondholders' protective committee, as endorsers. The notes not being paid, he filed suit thereon against the members of the committee, the corporation having been dissolved, and his administrator recovered judgment. This judgment was distributed to petitioner as sole beneficiary of her husband's estate. At that time it had no fair market value. Four years later a payment was made to petitioner on the judgment. Held, such payment is taxable to petitioner as…
1Opinion of the Court
OPINION.
KeRN, Judge:
In the stipulation of facts petitioner concedes that the portion of the payment to her representing a payment of interest is taxable as ordinary income. On brief she concedes that the portion of the payment applicable to the note made by the members of the bondholders’ protective committee is taxable as ordinary income. Therefore, the question left for our decision is whether the portion of the payment received by petitioner applicable to the principal of the four notes executed by the corporation, as maker, and the members of the committee, as endorsers, is taxable to her…
2Cases cited4 opinions
- Fairbanks v. United StatesSupreme Court of the United States · 1939
- Kanawha Valley Bank v. CommissionerUnited States Tax Court · 1944
- Lurie v. CommissionerUnited States Tax Court · 1945
- Rosenzweig v. CommissionerUnited States Tax Court · 1942
3Cited by9 opinions
- Milliken v. CommissionerUnited States Tax Court · 1950
- Hudson v. CommissionerUnited States Tax Court · 1953
- Estate of Martin v. CommissionerUnited States Tax Court · 1946
- Martin v. CommissionerUnited States Tax Court · 1946
- Hudson v. CommissionerUnited States Tax Court · 1953
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