White v. Commissioner
United States Board of Tax Appeals
In 1923 a partnership of which petitioners were members became involved in financial difficulties and executed notes in favor of its creditors. These notes bore interest. In the years 1923 to 1926 some payments were made on the principal and all interest was paid. This interest amounted to $16,134.02 and was taken as deductions in determining partnership income for the respective years when the interest was paid.
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In 1923 a partnership of which petitioners were members became involved in financial difficulties and executed notes in favor of its creditors. These notes bore interest. In the years 1923 to 1926 some payments were made on the principal and all interest was paid. This interest amounted to $16,134.02 and was taken as deductions in determining partnership income for the respective years when the interest was paid. In 1927 the partnership had a further agreement with its creditors by which it was agreed the partnership would execute one noninterest-bearing note for the amounts due its creditors…
1Opinion of the Court
OPINION.
Black :
These proceedings, which have been consolidated, are for the redetermination of deficiencies in income tax for 1930 in the respective amounts of $631.23 and $875.91. The only question presented for our determination is whether the respondent erred in adding to the partnership income reported by the petitioners for the taxable year their proportionate shares of the sum of $16,134.02, which amount was treated by the respondent as an increase in the partnership income growing out of a transaction by which, in pursuance of an agreement entered into in 1927 by the partnership and…
2Cases cited2 opinions
- Burnet v. Sanford & Brooks Co.Supreme Court of the United States · 1931
- United States v. Kirby Lumber CoSupreme Court of the United States · 1931
3Cited by9 opinions
- Walker v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1937
- Jelle v. CommissionerUnited States Tax Court · 2001
- Shannon v. CommissionerUnited States Tax Court · 1993
- Dennis and Dorinda J. Jelle v. CommissionerUnited States Tax Court · 2001
- Jelle v. CommissionerUnited States Tax Court · 2001
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