Dittmar v. Commissioner
United States Tax Court
Petitioner formed a wholly owned corporation to operate a sawmill and act as a source of lumber supply for his sole proprietorship retail lumber business. He invested $ 5,000 in the corporation's capital stock and made a total of 627 advances to the corporation throughout its life. The advances were for the purchase of capital equipment, for use as working capital, and to satisfy specific obligations which arose from time to time.
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Petitioner formed a wholly owned corporation to operate a sawmill and act as a source of lumber supply for his sole proprietorship retail lumber business. He invested $ 5,000 in the corporation's capital stock and made a total of 627 advances to the corporation throughout its life. The advances were for the purchase of capital equipment, for use as working capital, and to satisfy specific obligations which arose from time to time. Repayments of the advances were made by the corporation primarily in lumber. Petitioner continued to make advances to the corporation even though it operated at a…
1Opinion of the Court
OPINION.
Black, Judge:
On each of their joint returns for the calendar years 1948, 1949, and 1950, petitioner and his wife deducted as partial bad debts sums representing advances made by petitioner to Lone Star, his wholly owned sawmill corporation. Those deductions, which totaled $50,760, were disallowed by respondent.
Petitioner now contends that the entire $50,760 should be allowed as a bad debt deduction in 1950 and that respondent erred in failing to so allow it. He concedes that $1,606.25 in lumber was delivered by Lone Star in 1950, thereby reducing the balance of the advances due him…
2Cases cited11 opinions
- John Kelley Co. v. CommissionerSupreme Court of the United States · 1946
- Gooding Amusement Co. v. CommissionerUnited States Tax Court · 1954
- Schnitzer v. CommissionerUnited States Tax Court · 1949
- Matthiessen v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1952
- United States v. South Georgia Ry. Co.Court of Appeals for the Fifth Circuit · 1939
6 more not listed; retrieve them via the Exa API.
3Cited by18 opinions
- Wachovia Bank and Trust Company and George A. Shuford, Successor Cotrustees of the Evelyn Grove Seely Trust v. United StatesCourt of Appeals for the Fourth Circuit · 1961
- J. A. Maurer, Inc. v. CommissionerUnited States Tax Court · 1958
- Yale Ave. Corp. v. CommissionerUnited States Tax Court · 1972
- Byerlyte Corporation v. WilliamsDistrict Court, N.D. Ohio · 1959
- Christie Coal & Coke Co. v. CommissionerUnited States Tax Court · 1969
13 more not listed; retrieve them via the Exa API.