Mangrum v. Commissioner
United States Tax Court
1. Petitioners, over a two-year period, advanced in excess of $50,000 to a corporation in which they owned 50 percent of the stock and controlled the other stock. The alleged "loans" were not represented by notes, and no provision was made for the payment of interest. Petitioners took over the management and operation of the corporation and changed the name to reflect their interest.
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1. Petitioners, over a two-year period, advanced in excess of $50,000 to a corporation in which they owned 50 percent of the stock and controlled the other stock. The alleged "loans" were not represented by notes, and no provision was made for the payment of interest. Petitioners took over the management and operation of the corporation and changed the name to reflect their interest. Held, the advances were contributions to the capital of the corporation. 2. Where petitioners made only one loan in 1947 to their daughter, one loan in 1948 to a brother, seven loans in relatively small amounts…
1Opinion of the Court
Lloyd E. Mangrum and Eleta P. Mangrum v. Commissioner.
Mangrum v. Commissioner
Docket Nos. 69134, 75235.
United States Tax Court
T.C. Memo 1960-136; 1960 Tax Ct. Memo LEXIS 155; 19 T.C.M. (CCH) 700; T.C.M. (RIA) 60136;
June 27, 1960
1. Petitioners, over a two-year period, advanced in excess of $50,000 to a corporation in which they owned 50 percent of the stock and controlled the other stock. The alleged "loans" were not represented by notes, and no provision was made for the payment of interest. Petitioners took over the management and operation of the corporation and changed the name to reflect…
2Cases cited13 opinions
- Dallmeyer v. CommissionerUnited States Tax Court · 1950
- Boissevain v. CommissionerUnited States Tax Court · 1951
- Cluett v. CommissionerUnited States Tax Court · 1947
- Estate of Palmer v. CommissionerUnited States Tax Court · 1951
- Thomas v. CommissionerUnited States Tax Court · 1943
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