Lynch v. Commissioner
United States Tax Court
H entered into an arrangement with his closely held corporation, G, wherein he purchased property from G at a price which was less than its fair market value and borrowed money from a bank. H leased such property back to G and assigned the proceeds of the lease to the bank to repay the loan. G paid the premiums on H's personal life insurance policies which were also used to secure the loan. In addition, G paid for many of H's personal expenses.
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H entered into an arrangement with his closely held corporation, G, wherein he purchased property from G at a price which was less than its fair market value and borrowed money from a bank. H leased such property back to G and assigned the proceeds of the lease to the bank to repay the loan. G paid the premiums on H's personal life insurance policies which were also used to secure the loan. In addition, G paid for many of H's personal expenses. G later filed a voluntary petition in bankruptcy. Pursuant to the plan of arrangement, H sold his stock to C, and H was relieved of an undetermined…
1Opinion of the Court
CLAUD E. LYNCH and MANITA H. LYNCH, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Lynch v. Commissioner
Docket Nos. 4556-78, 19138-80.
United States Tax Court
T.C. Memo 1983-173; 1983 Tax Ct. Memo LEXIS 608; 45 T.C.M. (CCH) 1125; T.C.M. (RIA) 83173;
March 31, 1983.
H entered into an arrangement with his closely held corporation, G, wherein he purchased property from G at a price which was less than its fair market value and borrowed money from a bank. H leased such property back to G and assigned the proceeds of the lease to the bank to repay the loan. G paid the premiums on H's…
2Cases cited109 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
- Bixby v. CommissionerUnited States Tax Court · 1972
104 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- In Re BarryUnited States Bankruptcy Court, M.D. Tennessee · 1985