Shippen v. Commissioner
United States Tax Court
1. By agreement of petitioner and his partner, petitioner's capital account in the partnership was charged as of December 31, 1951, with the unpaid balance of certain cash advances made by the firm to one of its suppliers; and a contra credit was made on the same date to the supplier's account.
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1. By agreement of petitioner and his partner, petitioner's capital account in the partnership was charged as of December 31, 1951, with the unpaid balance of certain cash advances made by the firm to one of its suppliers; and a contra credit was made on the same date to the supplier's account. The reason for such action was, that petitioner had, in the partnership agreement, guaranteed collection of such accounts "in a reasonable time," and that the supplier had made no payment or shipments for credit to the account for at least 6 months. Held, that such charge to petitioner's capital…
1Opinion of the Court
Pierce, Judge:
Respondent determined deficiencies in petitioner’s income taxes, and also additions to tax, as follows:
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Claims made by petitioner to a net operating loss deduction for the year 1950, and also to a net operating loss deduction for the year 1952 as to which the respondent has made certain concessions, depend on the determination of other issues hereinafter mentioned; and, accordingly, such claims will be given consideration in connection with the computations to be made under Rule 50.
The issues presented for decision are:(1) Where petitioner had under the terms of an…
2Cases cited3 opinions
- Smith v. CommissionerUnited States Tax Court · 1953
- Trinco Industries, Inc. v. CommissionerUnited States Tax Court · 1954
- Thom v. BurnetDistrict Court, District of Columbia · 1932
3Cited by9 opinions
- Riss v. CommissionerUnited States Tax Court · 1971
- Milenbach v. CommissionerUnited States Tax Court · 1996
- Turner v. CommissionerUnited States Tax Court · 1960
- Edwards v. CommissionerUnited States Tax Court · 1959
- Milenbach v. CommissionerUnited States Tax Court · 1996
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