Siple v. Commissioner
United States Tax Court
In implementation of an agreement with a corporation and its majority stockholder to purchase stock in the corporation and otherwise to help it financially, petitioners furnished collateral so that the corporation could borrow from the bank with no personal liability on the part of petitioners.
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In implementation of an agreement with a corporation and its majority stockholder to purchase stock in the corporation and otherwise to help it financially, petitioners furnished collateral so that the corporation could borrow from the bank with no personal liability on the part of petitioners. The corporation suffered financial reverses and, as part of an agreement severing all business relations with the corporation and its majority stockholder, petitioners waived or released any rights they had, or might subsequently acquire, against either of them. Petitioners subsequently paid the bank…
1Opinion of the Court
J. Meredith Siple and Delia W. Siple, Petitioners v. Commissioner of Internal Revenue, Respondent
Siple v. Commissioner
Docket No. 5323-67
United States Tax Court
54 T.C. 1; 1970 U.S. Tax Ct. LEXIS 233;
January 14, 1970, Filed
Decision will be entered for the respondent.
In implementation of an agreement with a corporation and its majority stockholder to purchase stock in the corporation and otherwise to help it financially, petitioners furnished collateral so that the corporation could borrow from the bank with no personal liability on the part of petitioners. The corporation suffered financial…
Also in this document: Dissent.
2Cases cited25 opinions
- Putnam v. CommissionerSupreme Court of the United States · 1956
- Arrowsmith v. CommissionerSupreme Court of the United States · 1952
- Santa Anita Consol., Inc. v. CommissionerUnited States Tax Court · 1968
- Howell v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1934
- Martin v. CommissionerUnited States Tax Court · 1969
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