Bernstein v. Commissioner
United States Tax Court
Amount paid by corporation of which petitioner was sole stockholder in settlement of notes on which petitioner was guarantor constituted a dividend to petitioner. Petitioner has failed to establish that the amount of the payment in 1954 on corporate notes guaranteed by him was an allowable deduction.
1Opinion of the Court
Max Bernstein and Esther Bernstein v. Commissioner.
Bernstein v. Commissioner
Docket No. 74938.
United States Tax Court
T.C. Memo 1960-287; 1960 Tax Ct. Memo LEXIS 10; 19 T.C.M. (CCH) 1569; T.C.M. (RIA) 60287;
December 30, 1960
Amount paid by corporation of which petitioner was sole stockholder in settlement of notes on which petitioner was guarantor constituted a dividend to petitioner.
Petitioner has failed to establish that the amount of the payment in 1954 on corporate notes guaranteed by him was an allowable deduction.
Louis A. Reiss, Esq., and Harry Merdinger, C.P.A., 61 Broadway, New York,…
2Cases cited13 opinions
- Putnam v. CommissionerSupreme Court of the United States · 1956
- Wall v. United StatesCourt of Appeals for the Fourth Circuit · 1947
- Irving Sachs v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1960
- Sachs v. CommissionerUnited States Tax Court · 1959
- Max Putnam and Elizabeth Putnam v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1955
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