Tolzman v. Commissioner
United States Tax Court
Petitioner was president of ULT Co. but had no direct interest therein. However, he had a one-fourth interest in a partnership which owned 50 percent of ULT Co. Petitioner guaranteed notes of ULT Co. representing loans from a bank, and subsequently executed a deed of trust on his residence to secure the notes.
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Petitioner was president of ULT Co. but had no direct interest therein. However, he had a one-fourth interest in a partnership which owned 50 percent of ULT Co. Petitioner guaranteed notes of ULT Co. representing loans from a bank, and subsequently executed a deed of trust on his residence to secure the notes. ULT Co. became insolvent and ceased doing business in the latter part of 1969 but interest was paid on the notes up to December 1971. The bank assigned the notes and deed of trust to M, who demanded payment from petitioner and bought a foreclosure suit against petitioner in January 1972…
1Opinion of the Court
ALFRED H. TOLZMAN AND MILDRED B. TOLZMAN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Tolzman v. Commissioner
Docket No. 4668-78.
United States Tax Court
T.C. Memo 1981-689; 1981 Tax Ct. Memo LEXIS 53; 43 T.C.M. (CCH) 1; T.C.M. (RIA) 81689;
December 2, 1981.
Petitioner was president of ULT Co. but had no direct interest therein. However, he had a one-fourth interest in a partnership which owned 50 percent of ULT Co. Petitioner guaranteed notes of ULT Co. representing loans from a bank, and subsequently executed a deed of trust on his residence to secure the notes. ULT Co. became…
2Cases cited27 opinions
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- Trust Under the Will of Bingham v. CommissionerSupreme Court of the United States · 1945
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- United States v. GeneresSupreme Court of the United States · 1972
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