Legal Opinion

Hudson v. Commissioner

United States Tax Court

Decided July 27, 1994No. Docket No. 4272-92Published

Held, for Federal income tax purposes, purported promissory notes associated with petitioner's investment in educational master audio tapes do not constitute genuine indebtedness.

1Opinion of the Court

James L. Hudson, Petitioner v. Commissioner of Internal Revenue, Respondent

Hudson v. Commissioner

Docket No. 4272-92

United States Tax Court

103 T.C. 90; 1994 U.S. Tax Ct. LEXIS 48; 103 T.C. No. 7;

July 27, 1994, Filed

Decision will be entered under Rule 155.

Held, for Federal income tax purposes, purported promissory notes associated with petitioner's investment in educational master audio tapes do not constitute genuine indebtedness.

James L. Hudson, pro se.

T. Richard Sealy III, for respondent.

Swift, Judge.

SWIFT

Swift, Judge: Respondent determined deficiencies in and additions to petitioner's…

2Cases cited37 opinions

  1. Gregory v. HelveringSupreme Court of the United States · 1935
  2. Knetsch v. United StatesSupreme Court of the United States · 1960
  3. Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
  4. Crane v. CommissionerSupreme Court of the United States · 1947
  5. United States v. Kirby Lumber CoSupreme Court of the United States · 1931

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