Cornelius v. Commissioner
United States Tax Court
Held, where the basis of indebtedness of loans made by petitioners to a subch. S corporation had been reduced under sec. 1376(b), the repayment of such loans in a subsequent year resulted in the realization of taxable income.
1Opinion of the Court
Quealy, Judge:
The respondent has determined deficiencies in the Federal income taxes of the petitioners as follows:
Petitioner Docket No. Year Deficiency
Paul Q-. Cornelius, Sr., and Mary M. Cornelius... 105-70 1967 1 $59,526.95
Jack H. Cornelius and Betty J. Cornelius. 106-70 1967 30,489.58
The sole issue is whether the repayment of sums borrowed by Cornelius & Sons, Inc., from its shareholders resulted in the realization of income by the petitioners for the year 1967.
FINDINGS OF FACT
Some of the facts have been stipulated. The stipulation of facts and exhibits attached thereto are incorporated…
2Cases cited5 opinions
- Legg v. CommissionerUnited States Tax Court · 1971
- Darby Inv. Corp. v. CommissionerUnited States Tax Court · 1962
- Stinnett v. CommissionerUnited States Tax Court · 1970
- Smith v. CommissionerUnited States Tax Court · 1967
- Joe M. Smith and Florence P. Smith v. Commissioner of Internal Revenue, Henry v. Nielsen and Margaret E. Nielsen v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1970
3Cited by15 opinions
- Cornelius v. CommissionerCourt of Appeals for the Fifth Circuit · 1974
- Burnstein v. CommissionerUnited States Tax Court · 1984
- Nathel v. Comm'rUnited States Tax Court · 2008
- BROWN v. COMMISSION OF INTERNAL REVENUEUnited States Tax Court · 1981
- Paul G. Cornelius v. Commissioner Of Internal RevenueCourt of Appeals for the Fifth Circuit · 1974
10 more not listed; retrieve them via the Exa API.