Hubert Enters. v. Comm'r
United States Tax Court
A few individuals controlled a corporation (P1) and a limited liability company (ALSL). P1 transferred $ 2,440,684.38 to ALSL primarily to retransfer to a related limited partnership for use in the construction of a retirement community. The construction project was discontinued, and $ 2,397,266.32 of the transferred funds has not been repaid. P1 seeks to deduct those unrecovered funds as either a bad debt or a loss of capital/equity invested in ALSL.
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A few individuals controlled a corporation (P1) and a limited liability company (ALSL). P1 transferred $ 2,440,684.38 to ALSL primarily to retransfer to a related limited partnership for use in the construction of a retirement community. The construction project was discontinued, and $ 2,397,266.32 of the transferred funds has not been repaid. P1 seeks to deduct those unrecovered funds as either a bad debt or a loss of capital/equity invested in ALSL. P2 had a subsidiary (S) that was a member of a limited liability company (L) that was involved in equipment leasing activities most of which…
1Opinion of the Court
HUBERT ENTERPRISES, INC. AND SUBSIDIARIES, ET AL., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Hubert Enters. v. Comm'r
Nos. 4366-03, 10669-03, 16798-03
United States Tax Court
125 T.C. 72; 2005 U.S. Tax Ct. LEXIS 26; 125 T.C. No. 6;
September 21, 2005, Filed
A few individuals controlled a corporation (P1) and a limited
liability company (ALSL). P1 transferred $ 2,440,684.38 to ALSL
primarily to retransfer to a related limited partnership for use
in the construction of a retirement community. The construction
project was discontinued, and $ 2,397,266.32 of the transferred
funds has not…
2Cases cited42 opinions
- Williams v. TaylorSupreme Court of the United States · 2000
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- United States v. MenascheSupreme Court of the United States · 1955
- Montclair v. RamsdellSupreme Court of the United States · 1883
- Market Co. v. HoffmanSupreme Court of the United States · 1879
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