Brooks v. Commissioner
United States Tax Court
Petitioner was the majority shareholder and president of Corporation E. Corporation E was dependent upon sales to two major customers with whom it had no purchasing agreements.
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Petitioner was the majority shareholder and president of Corporation E. Corporation E was dependent upon sales to two major customers with whom it had no purchasing agreements. In order to reduce Corporation E's dependence on those customers, petitioner formed Corporation M which petitioner caused to acquire a chain of restaurants and become a captive customer of Corporation E. Petitioner guaranteed the promissory notes Corporation M issued in connection with the purchase of the restaurant chain. Corporation M was not successful and petitioner made payments on the notes as guarantor. Held:…
1Opinion of the Court
ROBERT H. AND YVONNE C. BROOKS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Brooks v. Commissioner
Docket No. 24893-88
United States Tax Court
T.C. Memo 1990-259; 1990 Tax Ct. Memo LEXIS 278; 59 T.C.M. (CCH) 682; T.C.M. (RIA) 90259;
May 29, 1990, Filed
Petitioner was the majority shareholder and president of Corporation E. Corporation E was dependent upon sales to two major customers with whom it had no purchasing agreements. In order to reduce Corporation E's dependence on those customers, petitioner formed Corporation M which petitioner caused to acquire a chain of restaurants and…
2Cases cited20 opinions
- Putnam v. CommissionerSupreme Court of the United States · 1956
- Pallottini v. CommissionerUnited States Tax Court · 1988
- United States v. GeneresSupreme Court of the United States · 1972
- Primuth v. CommissionerUnited States Tax Court · 1970
- Crown v. CommissionerUnited States Tax Court · 1981
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