Karme v. Commissioner
United States Tax Court
Held, a series of transactions whereby petitioner Alan B. Karme purportedly borrowed money to purchase stock did not create a genuine indebtedness with the result that petitioners are not entitled to a deduction in 1969 under sec. 163, I.R.C. 1954, for a purported $ 60,000 interest payment.
1Opinion of the Court
Featherston, Judge:
This case was tried before Special Trial Judge Lehman C. Aarons pursuant to Rule 180, Tax Court Rules of Practice and Procedure. His report was served on the parties. Petitioners filed exceptions, and respondent filed a brief in response to petitioners’ exceptions. After careful consideration, the Special Trial Judge’s report, which is set forth below, is adopted with minor modifications.
REPORT OF THE SPECIAL TRIAL JUDGE*
Aarons, Special Trial Judge:
Respondent determined a deficiency in petitioners’ Federal income tax for 1969 in the amount of $29,626 and an addition to tax…
2Cases cited43 opinions
- Parklane Hosiery Co. v. ShoreSupreme Court of the United States · 1979
- Gregory v. HelveringSupreme Court of the United States · 1935
- Elkins v. United StatesSupreme Court of the United States · 1960
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
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3Cited by107 opinions
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- Patin v. CommissionerUnited States Tax Court · 1987
- Foster v. Comm'rUnited States Tax Court · 1983
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