Davison v. Commissioner
United States Tax Court
W, a cash basis partnership, entered into an agreement in 1980 to borrow up to $ 29 million from J. J made an initial disbursement of $ 19,645,000. Pursuant to the loan agreement, J applied $ 227,647.22 of the initial disbursement as a credit for interest W owed to J on a previous loan.
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W, a cash basis partnership, entered into an agreement in 1980 to borrow up to $ 29 million from J. J made an initial disbursement of $ 19,645,000. Pursuant to the loan agreement, J applied $ 227,647.22 of the initial disbursement as a credit for interest W owed to J on a previous loan. Pursuant to a subsequent modification of the 1980 loan agreement, J agreed to advance $ 1,587,310.46 to W to enable W to satisfy its current interest obligation to J. J made a wire transfer of $ 1,587,310.46 to W's bank account on Dec. 30, 1980. On Dec. 31, 1980, W made a wire transfer to J to satisfy W's…
1Opinion of the Court
CHARLES H. DAVISON AND LESSIE B. DAVISON, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Davison v. Commissioner
Docket No. 15887-94.
United States Tax Court
107 T.C. 35; 1996 U.S. Tax Ct. LEXIS 35; 107 T.C. No. 4;
August 26, 1996, Filed
Decision will be entered under Rule 155.
W, a cash basis partnership, entered into an agreement in 1980 to borrow up to $ 29 million from J. J made an initial disbursement of $ 19,645,000. Pursuant to the loan agreement, J applied $ 227,647.22 of the initial disbursement as a credit for interest W owed to J on a previous loan. Pursuant to a subsequent…
2Cases cited21 opinions
- Minnesota Tea Co. v. HelveringSupreme Court of the United States · 1938
- Eckert v. BurnetSupreme Court of the United States · 1931
- Eli D. Goodstein v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. Eli D. GoodsteinCourt of Appeals for the First Circuit · 1959
- Helvering v. PriceSupreme Court of the United States · 1940
- Don E. Williams Co. v. CommissionerSupreme Court of the United States · 1977
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