Legal Opinion

MASSEY v. COMMISSIONER

United States Tax Court

Decided January 11, 1982No. Docket No. 11187-78UnpublishedCited by 2 opinions

Petitioner-husband made advances in 1972 through 1975 on behalf of Y Corporation to pay its creditors pursuant to prior commitments to them. He owned no stock in Y Corporation, but made the commitments to gain it as a client for X Corporation, in which he was a 50-percent shareholder through mid-December 1974, and 100-percent shareholder thereafter, and employed as an engineering and computer consultant.

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Petitioner-husband made advances in 1972 through 1975 on behalf of Y Corporation to pay its creditors pursuant to prior commitments to them. He owned no stock in Y Corporation, but made the commitments to gain it as a client for X Corporation, in which he was a 50-percent shareholder through mid-December 1974, and 100-percent shareholder thereafter, and employed as an engineering and computer consultant. Y Corporation had revenue only in two years of its existence and had no sales after some time in 1974. In 1974 and 1975, Y Corporation was insolvent and any suit by petitioner-husband to…

1Opinion of the Court

WILLIAM R. MASSEY AND SCHARLEEN B. MASSEY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

MASSEY v. COMMISSIONER

Docket No. 11187-78.

United States Tax Court

T.C. Memo 1982-9; 1982 Tax Ct. Memo LEXIS 739; 43 T.C.M. (CCH) 271; T.C.M. (RIA) 82009;

January 11, 1982.

Petitioner-husband made advances in 1972 through 1975 on behalf of Y Corporation to pay its creditors pursuant to prior commitments to them. He owned no stock in Y Corporation, but made the commitments to gain it as a client for X Corporation, in which he was a 50-percent shareholder through mid-December 1974, and 100-percent…

2Cases cited14 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Whipple v. CommissionerSupreme Court of the United States · 1963
  3. Putnam v. CommissionerSupreme Court of the United States · 1956
  4. United States v. GeneresSupreme Court of the United States · 1972
  5. Estate of Emerson v. CommissionerUnited States Tax Court · 1977

9 more not listed; retrieve them via the Exa API.

3Cited by2 opinions

  1. B.B. Rider Corp. v. CommissionerCourt of Appeals for the Third Circuit · 1984
  2. B.B. Rider Corporation v. Commissioner of Internal Revenue, Benjamin and Helen Stratmore v. Commissioner of Internal Revenue, B.B. Rider Corporation, A/K/A General Manufacturing Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1984

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