Siple v. Commissioner
United States Tax Court
In implementation of an agreement with a corporation and its majority stockholder to purchase stock in the corporation and otherwise to help it financially, petitioners furnished collateral so that the corporation could borrow from the bank with no personal liability on the part of petitioners.
Read the full summary
In implementation of an agreement with a corporation and its majority stockholder to purchase stock in the corporation and otherwise to help it financially, petitioners furnished collateral so that the corporation could borrow from the bank with no personal liability on the part of petitioners. The corporation suffered financial reverses and, as part of an agreement severing all business relations with the corporation and its majority stockholder, petitioners waived or released any rights they had, or might subsequently acquire, against either of them. Petitioners subsequently paid the bank…
1Opinion of the Court
OPINION
Tannenwald, Judge:
The respondent determined deficiencies in the petitioners’ income tax for the calendar years 1960, 1963, and 1964 in the respective amounts of $35,435.63, $343.25, and $16,262.54. All of the facts have been stipulated by the parties and accordingly the proceeding was submitted under Rule 30 of the Court’s Rules of Practice.
At the time of filing their petition, J. Meredith Siple and Delia W. Siple, husband and wife, were residents of Glendale, Calif. Their joint Federal income tax returns for the calendar years 1960, 1963, and 1964 were prepared and filed on the cash…
Also in this document: Concurrence.
2Cases cited20 opinions
- Putnam v. CommissionerSupreme Court of the United States · 1956
- Arrowsmith v. CommissionerSupreme Court of the United States · 1952
- Santa Anita Consol., Inc. v. CommissionerUnited States Tax Court · 1968
- Martin v. CommissionerUnited States Tax Court · 1969
- Shea v. CommissionerUnited States Tax Court · 1961
15 more not listed; retrieve them via the Exa API.
3Cited by25 opinions
- Markwardt v. CommissionerUnited States Tax Court · 1975
- Rushing v. CommissionerUnited States Tax Court · 1972
- Horne v. CommissionerUnited States Tax Court · 1972
- Anderson v. CommissionerUnited States Tax Court · 1971
- Ruby Smith Stahl v. United StatesCourt of Appeals for the D.C. Circuit · 1970
20 more not listed; retrieve them via the Exa API.