Legal Opinion

Bowen v. Commissioner

United States Tax Court

Decided August 12, 1974No. Docket No. 9353-72Unpublished

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.

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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

  1. Wichita Term. El. Co. v. Commissioner of Int. R.Court of Appeals for the Tenth Circuit · 1947
  2. John Kelley Co. v. CommissionerSupreme Court of the United States · 1946
  3. Burnet v. ClarkSupreme Court of the United States · 1932
  4. United States v. GeneresSupreme Court of the United States · 1972
  5. Litton Business Systems, Inc. v. CommissionerUnited States Tax Court · 1973

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