Wilson v. Commissioner
United States Tax Court
The petitioner, an attorney at law, prepared Federal income tax returns for many taxpayers, such returns disclosing refunds due. Such taxpayers then obtained from a bank of which the petitioner was an officer and substantial stockholder loans in the amount of the refunds disclosed, less, however, a "discount" retained by the bank, a charge for policies for life insurance on the lives of such taxpayers, and the amount of petitioner's fee for preparing the returns.
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The petitioner, an attorney at law, prepared Federal income tax returns for many taxpayers, such returns disclosing refunds due. Such taxpayers then obtained from a bank of which the petitioner was an officer and substantial stockholder loans in the amount of the refunds disclosed, less, however, a "discount" retained by the bank, a charge for policies for life insurance on the lives of such taxpayers, and the amount of petitioner's fee for preparing the returns. In each instance the note was made payable directly to the bank and the particular taxpayer involved executed a power of attorney…
1Opinion of the Court
AteiNS, Judge:
The respondent determined deficiencies in income tax in the amount of $2,278.07 and additions to tax on account of fraud in the amount of $1,139.03 for the taxable year 1958. At the trial the respondent conceded that no additions should be made on account of fraud. Other concessions having been made by both parties the issues remaining for decision are (1) whether petitioner received additional income as attorney fees and (2) whether petitioner sustained a deductible business bad debt loss.
FINDINGS OF FACT
Some of the facts have been stipulated and are incorporated herein by this…
2Cases cited11 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
- Corliss v. BowersSupreme Court of the United States · 1930
- Putnam v. CommissionerSupreme Court of the United States · 1956
- Burnet v. ClarkSupreme Court of the United States · 1932
6 more not listed; retrieve them via the Exa API.
3Cited by20 opinions
- Dri-Powr Distributors Asso. Trust v. CommissionerUnited States Tax Court · 1970
- Hudlow v. CommissionerUnited States Tax Court · 1971
- Brooks v. CommissionerUnited States Tax Court · 1968
- Wolder v. CommissionerUnited States Tax Court · 1972
- Baker v. CommissionerUnited States Tax Court · 1981
15 more not listed; retrieve them via the Exa API.