Estate of Byers v. Commissioner
United States Tax Court
Held, losses from the worthlessness of interest-free advances made by major stockholder and officer of a corporation to or on behalf of a customer of the corporation are deductible as nonbusiness bad debts.
1Opinion of the Court
Deennbn, Judge:
Respondent determined a deficiency of $22,043.76 in petitioners’ Federal income tax for 1965, all of which was placed in issue by the petition filed herein. At the time of trial, petitioner Frank M. Byers, Sr. (hereinafter referred to as petitioner), amended his petition to claim an overpayment of Federal income tax for 1965, as a result of his erroneous designation of $29,323.45 as a short-term capital loss on his 1965 return.
The issue presented for our decision is whether the losses sustained by petitioner in 1965 from his direct loans to J. W. Jaeger Co., from payments made…
2Cases cited25 opinions
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Higgins v. CommissionerSupreme Court of the United States · 1941
- Whipple v. CommissionerSupreme Court of the United States · 1963
- Putnam v. CommissionerSupreme Court of the United States · 1956
- Burnet v. ClarkSupreme Court of the United States · 1932
20 more not listed; retrieve them via the Exa API.
3Cited by24 opinions
- Imel v. CommissionerUnited States Tax Court · 1973
- Mann v. CommissionerUnited States Tax Court · 1975
- Young v. CommissionerUnited States Tax Court · 1974
- Haslam v. CommissionerUnited States Tax Court · 1974
- MASSEY v. COMMISSIONERUnited States Tax Court · 1982
19 more not listed; retrieve them via the Exa API.