Beckley v. Comm'r
United States Tax Court
Petitioner wife lent funds to a corporation in which petitioner husband was a shareholder. The corporation used the borrowed funds to develop a working model of Web-based video conferencing software. The corporation, however, had financial problems and was dissolved, and the working model was transferred to a second corporation in which petitioner husband was a shareholder. In 2001 and 2002, the second corporation made payments to petitioner wife.
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Petitioner wife lent funds to a corporation in which petitioner husband was a shareholder. The corporation used the borrowed funds to develop a working model of Web-based video conferencing software. The corporation, however, had financial problems and was dissolved, and the working model was transferred to a second corporation in which petitioner husband was a shareholder. In 2001 and 2002, the second corporation made payments to petitioner wife. Petitioners treated a portion of the payments petitioner wife received as taxable interest income and the balance as nontaxable repayment of funds…
1Opinion of the Court
Swift, Judge:
Respondent determined deficiencies m petitioners’ joint Federal income taxes and penalties as follows:
Penalty Year Deficiency sec. 6662(a)
$10,192 OO CO O ©Í to o o h-1
7,000 O O r-T bO o o to
The issue for decision is whether 50 percent of interest and loan principal that petitioner Virginia Beckley (Virginia) received in 2001 and 2002 also should be treated as taxable constructive corporate distributions to petitioner Alan Beck-ley (Alan).
Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references…
2Cases cited7 opinions
- Falsetti v. CommissionerUnited States Tax Court · 1985
- Magnon v. CommissionerUnited States Tax Court · 1980
- Meridian Wood Products Co., Inc., a Corporation v. United States of America, Harry F. Lenton and Colleen Lenton v. United StatesCourt of Appeals for the Ninth Circuit · 1984
- Feldman v. McGuireOregon Supreme Court · 1899
- Golden v. GoldenOregon Supreme Court · 1975
2 more not listed; retrieve them via the Exa API.
3Cited by2 opinions
- Alan Beckley and Virginia Johnston Beckley v. CommissionerUnited States Tax Court · 2008
- Beckley v. Comm'rUnited States Tax Court · 2008