HAWKINS v. COMMISSIONER
United States Tax Court
During 1965, petitioner-husband received in a corporate reorganization all the preferred stock of a construction company. The company defaulted on two loans in 1969 and 1971, which were guaranteed by petitioner-wife. Petitioner-wife repaid the principal and interest due on the loans.
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During 1965, petitioner-husband received in a corporate reorganization all the preferred stock of a construction company. The company defaulted on two loans in 1969 and 1971, which were guaranteed by petitioner-wife. Petitioner-wife repaid the principal and interest due on the loans. Petitioners also made various advances to the company during 1970 through 1974. During 1965 through 1974, the company made various large transfers to petitioners' sons; none of these transfers was repaid during those years. Held: (1) Neither petitioner-husband's stock nor any debts of the corporation to…
1Opinion of the Court
EARL G. HAWKINS AND ELVA L. HAWKINS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
HAWKINS v. COMMISSIONER
Docket Nos. 6256-70, 1486-72, 1499-72, 6213-76.
United States Tax Court
T.C. Memo 1987-91; 1987 Tax Ct. Memo LEXIS 87; 53 T.C.M. (CCH) 138; T.C.M. (RIA) 87091;
February 12, 1987.
During 1965, petitioner-husband received in a corporate reorganization all the preferred stock of a construction company. The company defaulted on two loans in 1969 and 1971, which were guaranteed by petitioner-wife. Petitioner-wife repaid the principal and interest due on the loans. Petitioners also…
2Cases cited32 opinions
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- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Greenberg's Express, Inc. v. CommissionerUnited States Tax Court · 1974
- Boehm v. CommissionerSupreme Court of the United States · 1945
- Bankers Pocahontas Coal Co. v. BurnetSupreme Court of the United States · 1932
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- Egly v. CommissionerUnited States Tax Court · 1988