Bradford v. Commissioner
United States Tax Court
Petitioner was indebted to a bank prior to 1938. In 1938, for personal business reasons of petitioner, promissory notes of petitioner's wife Eleanor were substituted for the notes of petitioner evidencing this indebtedness.
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Petitioner was indebted to a bank prior to 1938. In 1938, for personal business reasons of petitioner, promissory notes of petitioner's wife Eleanor were substituted for the notes of petitioner evidencing this indebtedness. This Court held in J. C. Bradford, 22 T.C. 1057, that the purchase from the bank of one of Eleanor's notes in the face amount of $ 100,000 for $ 50,000 in 1946 by petitioner's half brother with funds furnished by petitioner and his wife did not result in taxable income to petitioner in 1946 but did constitute taxable income to petitioner's wife in 1946. Respondent did not…
1Opinion of the Court
J. C. Bradford, Petitioner, v. Commissioner of Internal Revenue, Respondent
Bradford v. Commissioner
Docket No. 70400
United States Tax Court
34 T.C. 1051; 1960 U.S. Tax Ct. LEXIS 74;
September 16, 1960, Filed
Decision will be entered for the petitioner.
Petitioner was indebted to a bank prior to 1938. In 1938, for personal business reasons of petitioner, promissory notes of petitioner's wife Eleanor were substituted for the notes of petitioner evidencing this indebtedness. This Court held in J. C. Bradford, 22 T.C. 1057, that the purchase from the bank of one of Eleanor's notes in the face amount…
2Cases cited7 opinions
- Olin Mathieson Chemical Corporation v. United StatesCourt of Appeals for the Seventh Circuit · 1959
- Bradford v. CommissionerUnited States Tax Court · 1954
- Eleanor A. Bradford v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1956
- Bradford v. CommissionerUnited States Tax Court · 1960
- Bradford v. CommissionerUnited States Tax Court · 1960
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