Bradford v. Commissioner
United States Tax Court
Petitioner was indebted to a bank prior to 1938. In 1938, for personal business reasons of petitioner, promissory notes of petitioner's wife Eleanor were substituted for the notes of petitioner evidencing this indebtedness.
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Petitioner was indebted to a bank prior to 1938. In 1938, for personal business reasons of petitioner, promissory notes of petitioner's wife Eleanor were substituted for the notes of petitioner evidencing this indebtedness. This Court held in J. C. Bradford, 22 T.C. 1057, that the purchase from the bank of one of Eleanor's notes in the face amount of $ 100,000 for $ 50,000 in 1946 by petitioner's half brother with funds furnished by petitioner and his wife did not result in taxable income to petitioner in 1946 but did constitute taxable income to petitioner's wife in 1946. Respondent did not…
1Opinion of the Court
OPINION.
Drennen, Judge:
Respondent determined a deficiency in petitioner’s income tax for tbe year 1946 in tbe amount of $40,974.62.
Tbe issues raised by the pleadings are: (1) Whether petitioner received ordinary income in the amount of $50,000 in the year 1946 as a result of a transaction in which a $100,000 promissory note signed by his wife was discharged for $50,000; and (2) whether the assessment and collection of a deficiency for the taxable year 1946 is barred by the statute of limitations or is res judicata.
In view of our conclusion on the second issue, it will be unnecessary for us to…
2Cases cited6 opinions
- Olin Mathieson Chemical Corporation v. United StatesCourt of Appeals for the Seventh Circuit · 1959
- Bradford v. CommissionerUnited States Tax Court · 1954
- Eleanor A. Bradford v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1956
- Bradford v. CommissionerUnited States Tax Court · 1960
- Budd Co. v. CommissionerUnited States Tax Court · 1960
1 more not listed; retrieve them via the Exa API.
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- Weinrich v. CommissionerUnited States Tax Court · 1961
- Fruit of the Loom v. CommissionerUnited States Tax Court · 1994
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