Pachella v. Commissioner
United States Tax Court
1. On January 1, 1946, the petitioners Herbert A. Chary and Dominick F. Pachella formed a law partnership in the city of Hackensack, New Jersey. The law partnership for the most part specialized in real estate mortgage placement and represented banks, mortgage lending institutions, and individuals. On July 1, 1946, Chary, Pachella, and one Max Harrison organized a New Jersey corporation to carry on a drycleaning business.
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1. On January 1, 1946, the petitioners Herbert A. Chary and Dominick F. Pachella formed a law partnership in the city of Hackensack, New Jersey. The law partnership for the most part specialized in real estate mortgage placement and represented banks, mortgage lending institutions, and individuals. On July 1, 1946, Chary, Pachella, and one Max Harrison organized a New Jersey corporation to carry on a drycleaning business. Chary and Pachella were without experience in the drycleaning business and Harrison was placed in charge of operations. In 1949 Chary's wife was elected president of the…
1Opinion of the Court
OPINION.
Fay, Judge:
These proceedings involve deficiencies in income tax and additions to tax for the taxable years 1950 to 1955, inclusive, as follows:
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The only issue is whether the Commissioner erred in disallowing the amounts claimed as bad debt deductions by the law partnership of Pachella and Chary on the partnership returns for the taxable years 1950 to 1955, inclusive.
All the facts have been stipulated, are so found, and are incorporated herein by reference. Those necessary to an understanding of our inquiry are recited below.
The petitioners and the law partnership of…
2Cases cited30 opinions
- Spring City Foundry Co. v. CommissionerSupreme Court of the United States · 1934
- Putnam v. CommissionerSupreme Court of the United States · 1956
- Burnet v. ClarkSupreme Court of the United States · 1932
- Dalton v. BowersSupreme Court of the United States · 1932
- John M. Trent and Lisa M. Trent v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1961
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3Cited by44 opinions
- Crown v. CommissionerUnited States Tax Court · 1981
- Weddle v. CommissionerUnited States Tax Court · 1962
- Roth Steel Tube Company v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1980
- Horne v. CommissionerUnited States Tax Court · 1972
- Roth Steel Tube Co. v. CommissionerUnited States Tax Court · 1977
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