Crown v. Commissioner
United States Tax Court
Petitioner was called upon in 1965 to satisfy his guaranty of certain indebtedness to bank 1. Petitioner responded by delivering his personal note (appropriately collateralized) which was renewed at various times through 1966. On Dec. 30, 1966, petitioner satisfied his obligation ($ 2,697,131.31) to bank 1, with funds borrowed from bank 2 with which petitioner had a line of credit, the unused portion of which exceeded $ 39 million.
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Petitioner was called upon in 1965 to satisfy his guaranty of certain indebtedness to bank 1. Petitioner responded by delivering his personal note (appropriately collateralized) which was renewed at various times through 1966. On Dec. 30, 1966, petitioner satisfied his obligation ($ 2,697,131.31) to bank 1, with funds borrowed from bank 2 with which petitioner had a line of credit, the unused portion of which exceeded $ 39 million. The collateral securing the note at bank 1 was released into petitioner's control. On Mar. 1, 1967, petitioner borrowed sufficient funds from bank 1 to pay off the…
1Opinion of the Court
Henry Crown and Gladys K. Crown, Petitioners v. Commissioner of Internal Revenue, Respondent
Crown v. Commissioner
Docket No. 1588-77
United States Tax Court
77 T.C. 582; 1981 U.S. Tax Ct. LEXIS 59;
September 17, 1981, Filed
Decision will be entered under Rule 155.
Petitioner was called upon in 1965 to satisfy his guaranty of certain indebtedness to bank 1. Petitioner responded by delivering his personal note (appropriately collateralized) which was renewed at various times through 1966. On Dec. 30, 1966, petitioner satisfied his obligation ($ 2,697,131.31) to bank 1, with funds borrowed from bank 2…
2Cases cited29 opinions
- Crane v. CommissionerSupreme Court of the United States · 1947
- Putnam v. CommissionerSupreme Court of the United States · 1956
- Eckert v. BurnetSupreme Court of the United States · 1931
- Helvering v. PriceSupreme Court of the United States · 1940
- American Bantam Car Co. v. CommissionerUnited States Tax Court · 1948
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