Nichols v. Commissioner
United States Tax Court
1. Petitioner Darwin O. Nichols was a member of a partnership engaged in the manufacture of dies and metal stamps used in producing metal parts for other manufacturers to incorporate in their finished items. During 1949, petitioner purchased for the sum of $ 2,000 a 25 per cent stock interest in a newly organized corporation engaged in the business of painting and decorating metal and ceramic giftware. Petitioner was treasurer and a director of said corporation.
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1. Petitioner Darwin O. Nichols was a member of a partnership engaged in the manufacture of dies and metal stamps used in producing metal parts for other manufacturers to incorporate in their finished items. During 1949, petitioner purchased for the sum of $ 2,000 a 25 per cent stock interest in a newly organized corporation engaged in the business of painting and decorating metal and ceramic giftware. Petitioner was treasurer and a director of said corporation. Thereafter, until the end of the year, petitioner loaned funds to the corporation in the aggregate amount of $ 17,813.71. During…
1Opinion of the Court
FisheR, Judge:
Respondent determined deficiencies in income taxes against petitioners for the taxable year 1951 in the amount of $3,458.38.
The principal issue presented for our decision is whether the loss in 1951 resulting from worthlessness of the loans made by petitioner to a corporation, of which he was an officer-stockholder, is deductible as a business bad debt under section 23 (k) (1), as claimed by petitioner, or whether it is deductible as a nonbusiness bad debt within the meaning of section 23 (k) (4) as determined by respondent. Other issues involve (a) determination of amount of…
2Cases cited17 opinions
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Burnet v. ClarkSupreme Court of the United States · 1932
- Dalton v. BowersSupreme Court of the United States · 1932
- Campbell v. CommissionerUnited States Tax Court · 1948
- Boissevain v. CommissionerUnited States Tax Court · 1951
12 more not listed; retrieve them via the Exa API.
3Cited by12 opinions
- Pachella v. CommissionerUnited States Tax Court · 1961
- Rude v. CommissionerUnited States Tax Court · 1967
- Lundgren v. CommissionerUnited States Tax Court · 1965
- Barnard v. CommissionerUnited States Tax Court · 1963
- Dunn v. CommissionerUnited States Tax Court · 1963
7 more not listed; retrieve them via the Exa API.