Black v. Commissioner
United States Tax Court
Petitioners' testator prior to his death endorsed notes of X corporation payable to a bank. X had borrowed money from testator before this, giving him its notes. After testator's death X's net assets were only sufficient to pay 35 per cent of its general indebtedness.
Read the full summary
Petitioners' testator prior to his death endorsed notes of X corporation payable to a bank. X had borrowed money from testator before this, giving him its notes. After testator's death X's net assets were only sufficient to pay 35 per cent of its general indebtedness. Testator's estate, of which petitioners were residuary legatees, listed in its accounts and its estate tax return the amount payable on the endorsed notes at their face amount which was paid to the bank pursuant to claim filed, and listed as an asset the right to collect from X in the amount of 35 per cent of such amount.…
1Opinion of the Court
OPINION.
Kern, Judge:
These cases have been consolidated for hearing and opinion. They involve deficiencies determined by respondent in petitioners’ Federal income taxes for the years and in the amounts as follows:
[[Image here]]
All of the deficiencies arise by reason of respondent’s determinations that the basis of certain notes upon which (or upon the notes substituted therefor by the payor) petitioners Anna It. Black, Charlotte B. Murray, Alice B. Lewis, and Elizabeth B. Apsey received payments during the taxable years had a lesser basis in their hands than that used by them in computing…
2Cases cited8 opinions
- Davenport v. CommissionerUnited States Tax Court · 1946
- Du Val v. CommissionerUnited States Tax Court · 1945
- Du Val's Estate v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1945
- Parrott v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1929
- Atwell v. CommissionerUnited States Tax Court · 1952
3 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Black v. CommissionerUnited States Tax Court · 1960