Legal Opinion

Borggaard v. Commissioner

United States Tax Court

Decided November 19, 1979No. Docket No. 979-78Unpublished

1Opinion of the Court

HOWARD K. BORGGAARD & JEANNE BORGGAARD, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Borggaard v. Commissioner

Docket No. 979-78.

United States Tax Court

T.C. Memo 1979-458; 1979 Tax Ct. Memo LEXIS 72; 39 T.C.M. (CCH) 496; T.C.M. (RIA) 79458;

November 19, 1979, Filed

James J. Phillips, for the petitioners.

Barry J. Laterman, for the respondent.

RAUM

MEMORANDUM FINDINGS OF FACT AND OPINION

RAUM, Judge: The Commissioner determined a deficiency of $10,274.25 in the income tax of petitioners for 1973. At issue is the taxpayer's right to deduct certain payments made by his wholly-owned…

2Cases cited7 opinions

  1. Jergens v. CommissionerUnited States Tax Court · 1951
  2. Nye v. CommissionerUnited States Tax Court · 1968
  3. Kniffen v. CommissionerUnited States Tax Court · 1962
  4. D'Angelo Assoc., Inc. v. CommissionerUnited States Tax Court · 1978
  5. Citizens Nat. Trust & Savings Bank of Los Angeles v. WelchCourt of Appeals for the Ninth Circuit · 1941

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