Williams v. Commissioner
United States Tax Court
During the taxable years 1964 to 1969, inclusive, petitioners, husband and wife, as officers and majority shareholders of three family-owned corporations, withdrew large sums of corporate funds for their personal use, which were entered on the corporate books as accounts receivable and notes receivable. Notes were not issued until May 1967 for some, but not all, withdrawals. Notes were not issued until August 1969 for the remainder.
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During the taxable years 1964 to 1969, inclusive, petitioners, husband and wife, as officers and majority shareholders of three family-owned corporations, withdrew large sums of corporate funds for their personal use, which were entered on the corporate books as accounts receivable and notes receivable. Notes were not issued until May 1967 for some, but not all, withdrawals. Notes were not issued until August 1969 for the remainder. No interest was paid until after August 1969. A third party note was given the corporations by petitioners as repayment for the withdrawals after a reorganization…
1Opinion of the Court
C. F. WILLIAMS AND JEANNE V. WILLIAMS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Williams v. Commissioner
Docket No. 3589-74.
United States Tax Court
T.C. Memo 1978-306; 1978 Tax Ct. Memo LEXIS 206; 37 T.C.M. (CCH) 1270; T.C.M. (RIA) 78306;
August 8, 1978, Filed
During the taxable years 1964 to 1969, inclusive, petitioners, husband and wife, as officers and majority shareholders of three family-owned corporations, withdrew large sums of corporate funds for their personal use, which were entered on the corporate books as accounts receivable and notes receivable. Notes were not…
2Cases cited30 opinions
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- Roberts v. CommissionerUnited States Tax Court · 1974
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- Gene O. Clark and Faye Clark v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1959
- Fred M. Archer and Evie B. Archer v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1955
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