Legal Opinion

ATES v. COMMISSIONER

United States Tax Court

Decided September 9, 1985No. Docket No. 28440-82Unpublished

Held: (1) Ps are not entitled to deduct amounts purportedly loaned to their children. (2) The statute of limitations does not bar the assessment and collection of the deficiency.

1Opinion of the Court

LEROY D. and MILDRED F. ATES, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

ATES v. COMMISSIONER

Docket No. 28440-82.

United States Tax Court

T.C. Memo 1985-469; 1985 Tax Ct. Memo LEXIS 162; 50 T.C.M. (CCH) 1003; T.C.M. (RIA) 85469;

September 9, 1985.

Held: (1) Ps are not entitled to deduct amounts purportedly loaned to their children.(2) The statute of limitations does not bar the assessment and collection of the deficiency.

Leroy D. Ates, pro se.

Linda L. Wong, for the respondent.

SIMPSON

MEMORANDUM FINDINGS OF FACT AND OPINION

SIMPSON, Judge: The Commissioner determined a deficiency in…

2Cases cited4 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
  3. Dickman v. CommissionerSupreme Court of the United States · 1984
  4. Teil v. CommissionerUnited States Tax Court · 1979

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