Arrigoni v. Commissioner
United States Tax Court
Petitioners, as responsible officers of two corporations they owned which became insolvent, were assessed and paid both U.S. and Minnesota withholding taxes which were withheld by the corporations but not paid over and Minnesota sales taxes which were collected by one corporation but not paid over to the State, plus interest thereon. Held, petitioners are not entitled to deduct as bad debts the above taxes.
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Petitioners, as responsible officers of two corporations they owned which became insolvent, were assessed and paid both U.S. and Minnesota withholding taxes which were withheld by the corporations but not paid over and Minnesota sales taxes which were collected by one corporation but not paid over to the State, plus interest thereon. Held, petitioners are not entitled to deduct as bad debts the above taxes. Held, further, petitioners are not entitled to deduct the Minnesota withholding taxes withheld by the corporations but paid by petitioners under sec. 164(a)(3), I.R.C. 1954. Held, further,…
1Opinion of the Court
James M. Arrigoni and Delores E. Arrigoni, Petitioners v. Commissioner of Internal Revenue, Respondent
Arrigoni v. Commissioner
Docket No. 693-78
United States Tax Court
73 T.C. 792; 1980 U.S. Tax Ct. LEXIS 193;
February 6, 1980, Filed
Decision will be entered under Rule 155.
Petitioners, as responsible officers of two corporations they owned which became insolvent, were assessed and paid both U.S. and Minnesota withholding taxes which were withheld by the corporations but not paid over and Minnesota sales taxes which were collected by one corporation but not paid over to the State, plus interest…
2Cases cited22 opinions
- United States v. SoteloSupreme Court of the United States · 1978
- Edward J. Bloom v. United StatesCourt of Appeals for the Ninth Circuit · 1960
- Guardian Investment Corporation v. Robert L. Phinney, District Director of Internal RevenueCourt of Appeals for the Fifth Circuit · 1958
- Shiman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1932
- Rushing v. CommissionerUnited States Tax Court · 1972
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