Reid v. Commissioner
United States Tax Court
(1) Petitioner-husband and C incorporated two businesses (X and Y) in 1974. Petitioner-husband and C personally guaranteed X's debts under a factoring agreement with H. In 1976, H sued petitioner-husband, C, and X; later in 1976, H entered bankruptcy proceedings; in 1978, H's claim was released in exchange for release of a claim that X had filed against H. Held: Petitioners are not entitled to a deduction in 1975 on account of the foregoing.
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(1) Petitioner-husband and C incorporated two businesses (X and Y) in 1974. Petitioner-husband and C personally guaranteed X's debts under a factoring agreement with H. In 1976, H sued petitioner-husband, C, and X; later in 1976, H entered bankruptcy proceedings; in 1978, H's claim was released in exchange for release of a claim that X had filed against H. Held: Petitioners are not entitled to a deduction in 1975 on account of the foregoing. (2) In 1976, money judgments were rendered against petitioner-husband and others. Petitioners have not paid anything toward the judgments. Held:…
1Opinion of the Court
JOSEPH W. REID AND ALICE B. REID, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Reid v. Commissioner
Docket No. 316-78.
United States Tax Court
T.C. Memo 1981-677; 1981 Tax Ct. Memo LEXIS 68; 42 T.C.M. (CCH) 1741; T.C.M. (RIA) 81677;
November 24, 1981.(1) Petitioner-husband and C incorporated two businesses (X and Y) in 1974. Petitioner-husband and C personally guaranteed X's debts under a factoring agreement with H. In 1976, H sued petitioner-husband, C, and X; later in 1976, H entered bankruptcy proceedings; in 1978, H's claim was released in exchange for release of a claim that X…
2Cases cited31 opinions
- Helvering v. MitchellSupreme Court of the United States · 1938
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- Security Flour Mills Co. v. CommissionerSupreme Court of the United States · 1944
- Dixie Pine Products Co. v. CommissionerSupreme Court of the United States · 1944
- Strong v. CommissionerUnited States Tax Court · 1976
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