Jessup v. Commissioner
United States Tax Court
Held, petitioner has established the worthlessness of Haymac S.A. stock as of December 31, 1967. Held further, petitioner failed to sustain his burden of proving worthlessness of Universal Minerals and Metals, Inc. stock and notes. Held further, petitioner is engaged in the trade or business of lending, endorsing and guaranteeing; and loans to and guarantees made on behalf of Haymac S.A. and Mr. W. Hayden were proximately related to that business.
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Held, petitioner has established the worthlessness of Haymac S.A. stock as of December 31, 1967. Held further, petitioner failed to sustain his burden of proving worthlessness of Universal Minerals and Metals, Inc. stock and notes. Held further, petitioner is engaged in the trade or business of lending, endorsing and guaranteeing; and loans to and guarantees made on behalf of Haymac S.A. and Mr. W. Hayden were proximately related to that business. Held further, petitioner is not entitled to a total worthless bad debt deduction as he was holding valuable second mortgages and other collateral…
1Opinion of the Court
CLAUDE A. JESSUP and MAMIE A. JESSUP, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Jessup v. Commissioner
Docket No. 6751-75
United States Tax Court
T.C. Memo 1977-289; 1977 Tax Ct. Memo LEXIS 152; 36 T.C.M. (CCH) 1145; T.C.M. (RIA) 770289;
August 25, 1977, Filed As Amended September 8, 1977 As Amended November 17, 1977
Held, petitioner has established the worthlessness of Haymac S.A. stock as of December 31, 1967. Held further, petitioner failed to sustain his burden of proving worthlessness of Universal Minerals and Metals, Inc. stock and notes. Held further, petitioner is engaged…
2Cases cited21 opinions
- 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
- United States v. Simon W. Henderson, Jr., Independent for the Estate of Louise R. Henderson, DeceasedCourt of Appeals for the Fifth Circuit · 1967
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3Cited by2 opinions
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