Roussel v. Commissioner
United States Tax Court
In 1954, petitioner conducted a coffee brokerage business in his individual capacity, which business consisted mainly of acting as a local agent for Hard & Rand, Inc., a coffee importer. He also was manager and major shareholder of a corporation bearing his name which also bought and sold coffee. Both businesses were conducted from the same office, but separate books were maintained.
Read the full summary
In 1954, petitioner conducted a coffee brokerage business in his individual capacity, which business consisted mainly of acting as a local agent for Hard & Rand, Inc., a coffee importer. He also was manager and major shareholder of a corporation bearing his name which also bought and sold coffee. Both businesses were conducted from the same office, but separate books were maintained. In the latter part of 1954 the corporation, though solvent, was in need of cash and Hard & Rand, Inc., voluntarily loaned $ 75,000 to the corporation. Petitioner personally endorsed the note evidencing said loan…
1Opinion of the Court
W. D. and Sedley Roussel, Petitioners, v. Commissioner of Internal Revenue, Respondent
Roussel v. Commissioner
Docket No. 77992
United States Tax Court
37 T.C. 235; 1961 U.S. Tax Ct. LEXIS 30;
November 21, 1961, Filed
Decision will be entered under Rule 50.
In 1954, petitioner conducted a coffee brokerage business in his individual capacity, which business consisted mainly of acting as a local agent for Hard & Rand, Inc., a coffee importer. He also was manager and major shareholder of a corporation bearing his name which also bought and sold coffee. Both businesses were conducted from the same…
2Cases cited15 opinions
- Putnam v. CommissionerSupreme Court of the United States · 1956
- Snow v. CommissionerUnited States Tax Court · 1958
- L. Heller & Son, Inc. v. CommissionerUnited States Tax Court · 1949
- Trinco Industries, Inc. v. CommissionerUnited States Tax Court · 1954
- Sherman v. CommissionerUnited States Tax Court · 1952
10 more not listed; retrieve them via the Exa API.