Trent v. Commissioner
United States Tax Court
Bad debts arising from petitioner's loans to two related corporations of which he was an employee (as to one) and an officer (as to the other), held, nonbusiness bad debts.
1Opinion of the Court
OPINION.
Oppee, Judge:
It is petitioner’s contention that his unpaid loans to Caldwell, Inc., and Plastic in 1954 became worthless in 1955 and that they are business bad debts deductible in full under the statute.1 Respondent has determined that the debts were nonbusiness bad debts deductible only as capital losses and the case is presented to us on that issue alone.
Petitioner’s contention is based on his statement that he tentatively agreed at the time of his employment to lend financial aid to his employer’s business to an indefinite extent if and when circumstances should require it. He…
2Cases cited7 opinions
- Burnet v. ClarkSupreme Court of the United States · 1932
- Boissevain v. CommissionerUnited States Tax Court · 1951
- Skarda v. CommissionerUnited States Tax Court · 1956
- H. Beale Rollins and Mary E. Rollins v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1960
- Rollins v. CommissionerUnited States Tax Court · 1959
2 more not listed; retrieve them via the Exa API.
3Cited by50 opinions
- George P. Weddle and Bertha R. (Terris) Weddle v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1963
- Pachella v. CommissionerUnited States Tax Court · 1961
- Weddle v. CommissionerUnited States Tax Court · 1962
- Smith v. CommissionerUnited States Tax Court · 1970
- Hewett v. CommissionerUnited States Tax Court · 1967
45 more not listed; retrieve them via the Exa API.