Acker v. Commissioner
United States Tax Court
1. In 1947, a loan which petitioner had made to a corporation, of which he was a stockholder, became worthless; in 1948, petitioner made good on his guaranty of another corporation's loan. He was not in the business of financing corporations. Held, respondent properly allowed the deduction of such worthless debts as nonbusiness bad debts. 2. In 1947, 1948, and 1949, petitioner paid certain real property taxes owed by a corporation of which he was the sole stockholder.
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1. In 1947, a loan which petitioner had made to a corporation, of which he was a stockholder, became worthless; in 1948, petitioner made good on his guaranty of another corporation's loan. He was not in the business of financing corporations. Held, respondent properly allowed the deduction of such worthless debts as nonbusiness bad debts. 2. In 1947, 1948, and 1949, petitioner paid certain real property taxes owed by a corporation of which he was the sole stockholder. Held, such tax payments were not deductible by him under section 23(c). 3. In 1950, petitioner incurred legal expenses and…
1Opinion of the Court
Fred N. Acker v. Commissioner.
Acker v. Commissioner
Docket No. 53555.
United States Tax Court
T.C. Memo 1957-17; 1957 Tax Ct. Memo LEXIS 238; 16 T.C.M. (CCH) 89; T.C.M. (RIA) 57017;
January 28, 1957
1. In 1947, a loan which petitioner had made to a corporation, of which he was a stockholder, became worthless; in 1948, petitioner made good on his guaranty of another corporation's loan. He was not in the business of financing corporations. Held, respondent properly allowed the deduction of such worthless debts as nonbusiness bad debts.
2. In 1947, 1948, and 1949, petitioner paid certain real property…
2Cases cited11 opinions
- Commissioner v. HeiningerSupreme Court of the United States · 1943
- McCray v. United StatesSupreme Court of the United States · 1904
- Boissevain v. CommissionerUnited States Tax Court · 1951
- Sherman v. CommissionerUnited States Tax Court · 1952
- Stamos v. CommissionerUnited States Tax Court · 1954
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