Scifo v. Commissioner
United States Tax Court
Held: 1. Petitioners' losses as guarantors on obligations of World Foods, Inc., are deductible as nonbusiness bad debts. 2. Petitioners were the owners of 60,000 shares of the capital stock of World Foods, Inc., as of Dec. 31, 1970. 3. The stock of World Foods, Inc., was worthless as of Dec. 31, 1970. 4. Petitioners' investments in Scifo Enterprises, Ltd., were not worthless as of Dec. 31, 1970.
1Opinion of the Court
Drennen, Judge:
Respondent determined deficiencies in petitioners’ 1970 income tax liability as follows:
Docket No. Petitioners Deficiency
6788-75 Thomas P. Scifo and Aurora Scifo. $22,776
6789-75 Lewis P. Scifo and Norma E. Scifo. 22,634
The issues raised in these consolidated cases require us to decide:(1) Whether a payment by petitioners, as guarantors of a corporate note, gives rise to a business or nonbusiness bad debt deduction under section 166, I.R.C. 1954;1(2) Whether Thomas P. Scifo and Lewis P. Scifo, as individuals, were the owners of certain World Foods Corp. stock, and if so, whether…
2Cases cited9 opinions
- United States v. S. S. White Dental Manufacturing Co.Supreme Court of the United States · 1927
- Boehm v. CommissionerSupreme Court of the United States · 1945
- United States v. GeneresSupreme Court of the United States · 1972
- Morton v. CommissionerUnited States Board of Tax Appeals · 1938
- Morton v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1940
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3Cited by25 opinions
- Benak v. CommissionerUnited States Tax Court · 1981
- Baker v. CommissionerUnited States Tax Court · 1981
- Carter v. CommissionerUnited States Tax Court · 1979
- Garner v. CommissionerUnited States Tax Court · 1991
- HAWKINS v. COMMISSIONERUnited States Tax Court · 1987
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