Legal Opinion
United States v. Generes
Supreme Court of the United States
Decided March 27, 1972No. 70-28PublishedCited by 314 opinions
1Opinion of the CourtJustice Blackmun
A debt a closely held corporation owed to an indemnifying shareholder-employee became worthless in 1962. The issue in this federal income tax refund suit is whether, for the shareholder-employee, that worthless obligation was a business or a nonbusiness bad debt within the meaning and reach of §§ 166 (a) and (d) of the Internal Revenue Code of 1954, as amended, 26 *95U. S. C. §§ 166 (a) and (d),1 and of the implementing Regulations § 1.166-5.2
The issue’s resolution is important for the taxpayer. If the obligation was a business debt, he may use it to *96offset ordinary income and for carryback…
2Cases cited17 opinions
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Whipple v. CommissionerSupreme Court of the United States · 1963
- Putnam v. CommissionerSupreme Court of the United States · 1956
- Neely v. Martin K. Eby Construction Co., Inc.Supreme Court of the United States · 1967
- I. Hal Millsap, Jr., and Frances Millsap v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1968
12 more not listed; retrieve them via the Exa API.
3Cited by314 opinions
- Brunswick Corp. v. Pueblo Bowl-O-Mat, Inc.Supreme Court of the United States · 1977
- Houston Chronicle Publishing Company, Plaintiff-Appellee-Cross v. United States of America, Defendant-Appellant-CrossCourt of Appeals for the Fifth Circuit · 1973
- Charles A. Sammons, Individually, and Estate of Rosine S. Sammons, Deceased, Charles A. Sammons, Independent v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1973
- Harold Weisberg v. U.S. Department of JusticeCourt of Appeals for the D.C. Circuit · 1973
- Demes v. United StatesUnited States Court of Federal Claims · 2002
309 more not listed; retrieve them via the Exa API.