Putoma Corp. v. Commissioner
United States Tax Court
Individual petitioners Hunt and Purselley each owned 50 percent of the stock of petitioner corporations Putoma and Pro-Mac. Individual petitioners were also salaried employees of the two corporations. In 1970, Hunt and Purselley, cash basis taxpayers, canceled about $ 260,000 that petitioner corporations owed them for accrued but unpaid salaries and interest which the corporations had previously deducted.
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Individual petitioners Hunt and Purselley each owned 50 percent of the stock of petitioner corporations Putoma and Pro-Mac. Individual petitioners were also salaried employees of the two corporations. In 1970, Hunt and Purselley, cash basis taxpayers, canceled about $ 260,000 that petitioner corporations owed them for accrued but unpaid salaries and interest which the corporations had previously deducted. Held, petitioner corporations' obligation for accrued but unpaid compensation was conditional and not properly accruable during the years in question. Held, further, cancellation of the…
1Opinion of the Court
Putoma Corporation, Successor by Merger of Pro-Mac Company, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent
Putoma Corp. v. Commissioner
Docket Nos. 7468-73, 7469-73, 7470-73, 7471-73, 7472-73
United States Tax Court
66 T.C. 652; 1976 U.S. Tax Ct. LEXIS 78;
June 30, 1976, Filed
Decisions will be entered under Rule 155.
Individual petitioners Hunt and Purselley each owned 50 percent of the stock of petitioner corporations Putoma and Pro-Mac. Individual petitioners were also salaried employees of the two corporations. In 1970, Hunt and Purselley, cash basis taxpayers, canceled…
Also in this document: Dissent.
2Cases cited85 opinions
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Eisner v. MacOmberSupreme Court of the United States · 1920
- Helvering v. HorstSupreme Court of the United States · 1940
- United States v. AndersonSupreme Court of the United States · 1926
- Dobson v. CommissionerSupreme Court of the United States · 1944
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