Legal Opinion

Hogue v. Commissioner

United States Tax Court

Decided April 19, 1971No. Docket No. 5967-68Unpublished

Petitioner, a CPA, helped to initiate several corporations. One of these, A corp., never began the active conduct of business. When one of the owners of one of petitioner's clients (B corp.) wished to sell his interest petitioner arranged a transaction with A, so that A became the controlling shareholder.

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Petitioner, a CPA, helped to initiate several corporations. One of these, A corp., never began the active conduct of business. When one of the owners of one of petitioner's clients (B corp.) wished to sell his interest petitioner arranged a transaction with A, so that A became the controlling shareholder. Petitioner was in control of A. Held, notes signed by petitioner as guarantor of B corp. were loans, not contributions to capital and petitioner's payment thereof gave rise to a nonbusiness bad debt, not a business bad debt, since there was no proximate relationship between petitioner's…

1Opinion of the Court

Ross D. Hogue and Mildred M. Hogue v. Commissioner.

Hogue v. Commissioner

Docket No. 5967-68.

United States Tax Court

T.C. Memo 1971-75; 1971 Tax Ct. Memo LEXIS 256; 30 T.C.M. (CCH) 311; T.C.M. (RIA) 71075;

April 19, 1971, Filed

Petitioner, a CPA, helped to initiate several corporations. One of these, A corp., never began the active conduct of business. When one of the owners of one of petitioner's clients (B corp.) wished to sell his interest petitioner arranged a transaction with A, so that A became the controlling shareholder. Petitioner was in control of A. Held, notes signed by petitioner as…

2Cases cited4 opinions

  1. Whipple v. CommissionerSupreme Court of the United States · 1963
  2. Bart v. CommissionerUnited States Tax Court · 1954
  3. Smith v. CommissionerUnited States Tax Court · 1970
  4. Garlove v. CommissionerUnited States Tax Court · 1965

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