Gawler v. Commissioner
United States Tax Court
Petitioners, as members of an investment group, entered into an agreement with the shareholders of a Costa Rican corporation which owned and operated a sugar mill pursuant to which they promised to contribute an unspecified amount of money to an attempt to make the mill achieve certain production quotas in return for 55-percent ownership in the stock of the corporation if the quotas were met.
Read the full summary
Petitioners, as members of an investment group, entered into an agreement with the shareholders of a Costa Rican corporation which owned and operated a sugar mill pursuant to which they promised to contribute an unspecified amount of money to an attempt to make the mill achieve certain production quotas in return for 55-percent ownership in the stock of the corporation if the quotas were met. During the 1964-65 cutting and grinding season, petitioners provided their financial advice and $ 105,000 to the effort to revitalize the sugar mill. At the end of the season, the mill had failed to…
1Opinion of the Court
Tannenwald, Judge:
Respondent determined deficiencies in the income taxes of petitioners for the year 1965 in the following amounts:
Docket No. Petitioners Addition to Deficiency tax sec. 6651(a) 6029-69 John P. Gawler and Annabel C. Gawler....- $11,977.66 .. 6030-69 Robert H. Myers and Antoinette H. Myers... 6,071.43 . 6031-69 Katherine L. Simmons.. 592.37 $59.24 6032-69 John H. Myers and Eleanor B. Myers. 983.20 . 6033-69 Berkeley L. Simmons, Jr., and Virginia T. Simmons. 1,339.79 .- 6034-69 Robert L. Simmons __.-. 595.38 .-
The sole question presented is whether losses attributable to…
2Cases cited12 opinions
- De Woskin v. CommissionerUnited States Tax Court · 1960
- W. A. Drake, Inc. v. CommissionerUnited States Tax Court · 1944
- June M. Carlberg, by Vida M. Frick, Guardian v. United StatesCourt of Appeals for the Eighth Circuit · 1960
- Schultz v. CommissionerUnited States Tax Court · 1968
- Seed v. CommissionerUnited States Tax Court · 1969
7 more not listed; retrieve them via the Exa API.
3Cited by12 opinions
- Lorch v. CommissionerUnited States Tax Court · 1978
- Fred H. Lenway & Co. v. CommissionerUnited States Tax Court · 1978
- Hunter v. CommissionerUnited States Tax Court · 1982
- Datamation Services, Inc. v. CommissionerUnited States Tax Court · 1976
- Fred H. Lenway & Co. v. CommissionerUnited States Tax Court · 1978
7 more not listed; retrieve them via the Exa API.