Legal Opinion

Quinn v. Commissioner

United States Tax Court

Decided May 15, 1974No. Docket No. 4390-68Published

Howard B. Quinn, chairman of the board of directors of a savings and loan association, in 1963 caused the association to pay him $ 553,166.66, purportedly as advance rent on a building which he had leased to the association. The board of directors insisted that he restore the money. He repaid $ 53,166.66 but gave a note for the balance of $ 500,000 during the tax year.

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Howard B. Quinn, chairman of the board of directors of a savings and loan association, in 1963 caused the association to pay him $ 553,166.66, purportedly as advance rent on a building which he had leased to the association. The board of directors insisted that he restore the money. He repaid $ 53,166.66 but gave a note for the balance of $ 500,000 during the tax year. He and Mrs. Quinn filed a joint return for 1963 which did not report the $ 500,000 as income but mentioned it in an attached statement. It is held: 1. The facts in this case are distinguishable from those in Wilbur Buff, 58…

1Opinion of the Court

Howard B. Quinn and Charlotte J. Quinn, Petitioners v. Commissioner of Internal Revenue, Respondent

Quinn v. Commissioner

Docket No. 4390-68

United States Tax Court

62 T.C. 223; 1974 U.S. Tax Ct. LEXIS 111; 62 T.C. No. 25;

May 15, 1974, Filed

Decision will be entered under Rule 155.

Howard B. Quinn, chairman of the board of directors of a savings and loan association, in 1963 caused the association to pay him $ 553,166.66, purportedly as advance rent on a building which he had leased to the association. The board of directors insisted that he restore the money. He repaid $ 53,166.66 but gave a note…

2Cases cited18 opinions

  1. North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
  2. Brushaber v. Union Pacific RailroadSupreme Court of the United States · 1916
  3. James v. United StatesSupreme Court of the United States · 1961
  4. Sonnenborn v. CommissionerUnited States Tax Court · 1971
  5. United States v. Maryland Savings-Share Ins. Corp.Supreme Court of the United States · 1970

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