Bowen v. Commissioner
United States Tax Court
X made a $20,000 advance to W corporation for which he received a promissory note. Y, co-equal shareholder with X in W corporation, made an identical advance. W corporation never paid any dividends to X or Y. Held, the $20,000 advance by X represented a contribution to capital. X and Y agreed to indemnify a surety company on a performance and labor bond for W corporation. X and Y also cosigned a loan from C bank to W corporation.
Read the full summary
X made a $20,000 advance to W corporation for which he received a promissory note. Y, co-equal shareholder with X in W corporation, made an identical advance. W corporation never paid any dividends to X or Y. Held, the $20,000 advance by X represented a contribution to capital. X and Y agreed to indemnify a surety company on a performance and labor bond for W corporation. X and Y also cosigned a loan from C bank to W corporation. After W corporation became insolvent, X expended funds pursuant to the bond and the loan agreements. Held, expenditures made by X are deductible as nonbusiness bad…
1Opinion of the Court
H. LESLIE BOWEN AND ESTHER L. BOWEN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Bowen v. Commissioner
Docket No. 9353-72.
United States Tax Court
T.C. Memo 1974-208; 1974 Tax Ct. Memo LEXIS 111; 33 T.C.M. (CCH) 932; T.C.M. (RIA) 74208;
August 12, 1974, Filed.
X made a $20,000 advance to W corporation for which he received a promissory note. Y, co-equal shareholder with X in W corporation, made an identical advance. W corporation never paid any dividends to X or Y. Held, the $20,000 advance by X represented a contribution to capital.
X and Y agreed to indemnify a surety company on a…
2Cases cited15 opinions
- Wichita Term. El. Co. v. Commissioner of Int. R.Court of Appeals for the Tenth Circuit · 1947
- John Kelley Co. v. CommissionerSupreme Court of the United States · 1946
- Burnet v. ClarkSupreme Court of the United States · 1932
- United States v. GeneresSupreme Court of the United States · 1972
- Litton Business Systems, Inc. v. CommissionerUnited States Tax Court · 1973
10 more not listed; retrieve them via the Exa API.