Legal Opinion

Carter v. Commissioner

United States Tax Court

Decided November 8, 1979No. Docket No. 1515-77UnpublishedCited by 1 opinion

Petitioner started two companies primarily in order to provide himself with a salary rather than as an investment. Petitioner loaned money to two key employees to invest in the companies. These loans become uncollectible. Held: the loans were made predominately to protect petitioner's status as an employee and are deductible as business bad debts.

1Opinion of the Court

CHARLES W. and JANE D. CARTER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Carter v. Commissioner

Docket No. 1515-77.

United States Tax Court

T.C. Memo 1979-447; 1979 Tax Ct. Memo LEXIS 79; 39 T.C.M. (CCH) 456; T.C.M. (RIA) 79447;

November 8, 1979, Filed

Petitioner started two companies primarily in order to provide himself with a salary rather than as an investment. Petitioner loaned money to two key employees to invest in the companies. These loans become uncollectible. Held: the loans were made predominately to protect petitioner's status as an employee and are deductible as…

2Cases cited11 opinions

  1. Whipple v. CommissionerSupreme Court of the United States · 1963
  2. United States v. GeneresSupreme Court of the United States · 1972
  3. Millsap v. CommissionerUnited States Tax Court · 1966
  4. I. Hal Millsap, Jr., and Frances Millsap v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1968
  5. John M. Trent and Lisa M. Trent v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1961

6 more not listed; retrieve them via the Exa API.

3Cited by1 opinion

  1. Harry Litwin v. United StatesCourt of Appeals for the Tenth Circuit · 1993

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