Zappo v. Commissioner
United States Tax Court
Zappo and Murphy formed Company to construct and sell townhouses. New Investors entered the venture by purchasing shares of Company and lending money to Zappo and Murphy. Later, New Investors had a disagreement with Zappo and Murphy relating to Company and repayment of the loans.
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Zappo and Murphy formed Company to construct and sell townhouses. New Investors entered the venture by purchasing shares of Company and lending money to Zappo and Murphy. Later, New Investors had a disagreement with Zappo and Murphy relating to Company and repayment of the loans. The disagreement was resolved under a settlement agreement, whereby Zappo and Murphy transferred their Company shares to New Investors, and New Investors released Zappo and Murphy from their prior loan obligations. On the same date, Company sold incomplete townhouses to N.V.T.H. in exchange for cash and a contingent…
1Opinion of the Court
Angelo Zappo and Dorothy Zappo, Petitioners v. Commissioner of Internal Revenue, Respondent
Zappo v. Commissioner
Docket No. 6436-78
United States Tax Court
81 T.C. 77; 1983 U.S. Tax Ct. LEXIS 59; 81 T.C. No. 7;
August 3, 1983, Filed
Decision will be entered under Rule 155.
Zappo and Murphy formed Company to construct and sell townhouses. New Investors entered the venture by purchasing shares of Company and lending money to Zappo and Murphy. Later, New Investors had a disagreement with Zappo and Murphy relating to Company and repayment of the loans. The disagreement was resolved under a settlement…
2Cases cited30 opinions
- Crane v. CommissionerSupreme Court of the United States · 1947
- United States v. Kirby Lumber CoSupreme Court of the United States · 1931
- Eckert v. BurnetSupreme Court of the United States · 1931
- Helvering v. PriceSupreme Court of the United States · 1940
- American Bantam Car Co. v. CommissionerUnited States Tax Court · 1948
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