Young v. Commissioner
United States Tax Court
The petitioner made payments to two bonding companies and a bank as required by indemnity and guaranty agreements which he signed for two corporations in which he was both an investor and an employee. Held: The debts created by payments required by these agreements were proximately related to the petitioner's trade or business and are, therefore, deductible as business bad debts under the provisions of sec. 166(a).
1Opinion of the Court
WILLIAM G. YOUNG and NANCY YOUNG, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Young v. Commissioner
Docket No. 7764-70
United States Tax Court
T.C. Memo 1974-76; 1974 Tax Ct. Memo LEXIS 239; 33 T.C.M. (CCH) 397; T.C.M. (RIA) 74076;
March 28, 1974, Filed.
The petitioner made payments to two bonding companies and a bank as required by indemnity and guaranty agreements which he signed for two corporations in which he was both an investor and an employee. Held: The debts created by payments required by these agreements were proximately related to the petitioner's trade or business and…
2Cases cited15 opinions
- United States v. GeneresSupreme Court of the United States · 1972
- Primuth v. CommissionerUnited States Tax Court · 1970
- Millsap v. CommissionerUnited States Tax Court · 1966
- I. Hal Millsap, Jr., and Frances Millsap v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1968
- John M. Trent and Lisa M. Trent v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1961
10 more not listed; retrieve them via the Exa API.
3Cited by4 opinions
- Estate of Guy L. Mann, Deceased. Suzanne Mann Duval, Administratrix v. United StatesCourt of Appeals for the Fifth Circuit · 1984
- B.B. Rider Corp. v. CommissionerCourt of Appeals for the Third Circuit · 1984
- James C. And Lillian Garner v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1993
- B.B. Rider Corporation v. Commissioner of Internal Revenue, Benjamin and Helen Stratmore v. Commissioner of Internal Revenue, B.B. Rider Corporation, A/K/A General Manufacturing Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1984