Estate of Williamson v. Commissioner
United States Tax Court
1. An amount credited to petitioner's partnership capital account, held, to be additional taxable income in absence of contrary proof. 2. Cash basis seller required by purchaser to leave proceeds of corporate stock sale for disbursement to the corporation as a loan on open account, held, not to have realized income in year of sale in the absence of collection of debt from corporation. 3. Advances by petitioner to a corporation which subsequently became insolvent, held, not…
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1. An amount credited to petitioner's partnership capital account, held, to be additional taxable income in absence of contrary proof. 2. Cash basis seller required by purchaser to leave proceeds of corporate stock sale for disbursement to the corporation as a loan on open account, held, not to have realized income in year of sale in the absence of collection of debt from corporation. 3. Advances by petitioner to a corporation which subsequently became insolvent, held, not deductible either as a loss or as a business bad debt.
1Opinion of the Court
Estate of W. F. Williamson, Deceased, Paula R. Williamson, Administratrix, et al., * Petitioner, v. Commissioner of Internal Revenue, Respondent
Estate of Williamson v. Commissioner
Docket Nos. 54540, 54541, 54542
United States Tax Court
29 T.C. 51; 1957 U.S. Tax Ct. LEXIS 62;
October 17, 1957, Filed
Decisions will be entered under Rule 50.
1. An amount credited to petitioner's partnership capital account, held, to be additional taxable income in absence of contrary proof.
2. Cash basis seller required by purchaser to leave proceeds of corporate stock sale for disbursement to the corporation as a…
Also in this document: Dissent.
2Cases cited17 opinions
- Campbell v. CommissionerUnited States Tax Court · 1948
- Boissevain v. CommissionerUnited States Tax Court · 1951
- Towers v. CommissionerUnited States Tax Court · 1955
- Commissioner of Internal Revenue v. SmithCourt of Appeals for the Second Circuit · 1953
- Smith v. CommissionerUnited States Tax Court · 1951
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