Legal Opinion

Lorch v. Commissioner

United States Tax Court

Decided August 15, 1978No. Docket Nos. 5315-75, 9654-75Published

In 1962, petitioners entered into an arrangement whereby cash and securities owned by them (approximately $ 100,000 in value for each) would be held by HS, would be subordinated to the claims of HS' creditors, and, upon notification of HS, would be liquidated and the proceeds utilized by HS. Petitioners were to be paid $ 5,000 annually by HS under the arrangement.

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In 1962, petitioners entered into an arrangement whereby cash and securities owned by them (approximately $ 100,000 in value for each) would be held by HS, would be subordinated to the claims of HS' creditors, and, upon notification of HS, would be liquidated and the proceeds utilized by HS. Petitioners were to be paid $ 5,000 annually by HS under the arrangement. In the event that petitioners' securities were liquidated, they would be entitled to receive subordinated debentures in the face amount of the proceeds of liquidation and cash deposited with HS. HS gave the necessary notice to…

1Opinion of the Court

Joseph Lorch and Hannah Lorch, Petitioners v. Commissioner of Internal Revenue, Respondent; Michael T. Harges and Janet G. Harges, Petitioners v. Commissioner of Internal Revenue, Respondent

Lorch v. Commissioner

Docket Nos. 5315-75, 9654-75

United States Tax Court

70 T.C. 674; 1978 U.S. Tax Ct. LEXIS 78;

August 15, 1978, Filed

Decision will be entered for the respondent in docket No. 5315-75.

Decision will be entered under Rule 155 in docket No. 9654-75.

In 1962, petitioners entered into an arrangement whereby cash and securities owned by them (approximately $ 100,000 in value for each) would be…

2Cases cited28 opinions

  1. Helvering v. Southwest Consolidated Corp.Supreme Court of the United States · 1942
  2. Bazley v. CommissionerSupreme Court of the United States · 1947
  3. Santa Anita Consol., Inc. v. CommissionerUnited States Tax Court · 1968
  4. Commissioner of Internal Revenue v. Neustadt's TrustCourt of Appeals for the Second Circuit · 1942
  5. Jordan v. CommissionerUnited States Tax Court · 1973

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