Gillespie v. Commissioner
United States Tax Court
Petitioners were the principal stockholders and directors of Gillespie Equipment, Inc. Robert E. Gillespie was also a salaried executive of that company. Advances made to the company, and the payment, as guarantors, of corporate debt gave rise to bad debts. Held, the losses were nonbusiness bad debts inasmuch as such losses were not proximately related to a trade or business of the petitioners.
1Opinion of the Court
OPINION
The petitioners owned or controlled all of the stock of Gillespie Equipment, Inc. That corporation obtained a loan of $60,000 from Trans-America Equity for which it issued $60,000 face amount of convertible debentures, secured by the guaranty of the petitioners to the extent of the value of certain collateral. The collateral consisted of all of the stock of Gillespie Decals, Inc., all of the stock of Gillespie Properties, Inc., all of .the stock of Gillespie Equipment, Inc., and a second mortgage on certain real property owned by the petitioners. The value of the collateral was…
2Cases cited11 opinions
- Whipple v. CommissionerSupreme Court of the United States · 1963
- Putnam v. CommissionerSupreme Court of the United States · 1956
- John M. Trent and Lisa M. Trent v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1961
- George P. Weddle and Bertha R. (Terris) Weddle v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1963
- Trent v. CommissionerUnited States Tax Court · 1960
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3Cited by26 opinions
- United States v. GeneresSupreme Court of the United States · 1972
- Horne v. CommissionerUnited States Tax Court · 1972
- Holbrook v. CommissionerUnited States Tax Court · 1970
- Mann v. CommissionerUnited States Tax Court · 1975
- Haslam v. CommissionerUnited States Tax Court · 1974
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