Madden v. Commissioner
United States Tax Court
Petitioner, Dr. Madden, loaned money to a friend to meet the expenses of his two automobile dealerships, and later acquired controlling interest in both corporations.
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Petitioner, Dr. Madden, loaned money to a friend to meet the expenses of his two automobile dealerships, and later acquired controlling interest in both corporations. Madden continued to advance money to the two corporations, but both of them went out of business, one in 1970 and the other in 1976. Held, Madden's advances were contributions to the capital of the two corporations and his losses are not deductible as business losses, business bad debts or business expenses; held further, petitioners realized a capital gain on the sale of real estate in 1971; held further, additions to tax under…
1Opinion of the Court
ROBERT MADDEN and EDITH MADDEN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Madden v. Commissioner
Docket No. 3947-78.
United States Tax Court
T.C. Memo 1980-350; 1980 Tax Ct. Memo LEXIS 233; 40 T.C.M. (CCH) 1103; T.C.M. (RIA) 80350;
September 2, 1980, Filed
Petitioner, Dr. Madden, loaned money to a friend to meet the expenses of his two automobile dealerships, and later acquired controlling interest in both corporations. Madden continued to advance money to the two corporations, but both of them went out of business, one in 1970 and the other in 1976. Held, Madden's advances were…
2Cases cited37 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Bixby v. CommissionerUnited States Tax Court · 1972
- Whipple v. CommissionerSupreme Court of the United States · 1963
32 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- J.R. Betson, Jr. And Joan Sue Betson v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1986