Larkin v. Commissioner
United States Board of Tax Appeals
Petitioner and others executed a joint note to a bank for the purpose of acquiring stock then pledged by other borrowers as security for their loan. The amount of the loan to petitioner and his associates was applied in cancellation and satisfaction of the note of the parties from whom the stock was being purchased and the stock was retained by the bank as collateral to the new loan.
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Petitioner and others executed a joint note to a bank for the purpose of acquiring stock then pledged by other borrowers as security for their loan. The amount of the loan to petitioner and his associates was applied in cancellation and satisfaction of the note of the parties from whom the stock was being purchased and the stock was retained by the bank as collateral to the new loan. Subsequently the original note of petitioner and his associates was canceled and separate notes were executed by each, secured by an aliquot part of the collateral then held by the bank, petitioner having also…
1Opinion of the Court
J. J. LARKIN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Larkin v. Commissioner
Docket No. 102593.
United States Board of Tax Appeals
46 B.T.A. 213; 1942 BTA LEXIS 898;
January 27, 1942, Promulgated
Petitioner and others executed a joint note to a bank for the purpose of acquiring stock then pledged by other borrowers as security for their loan. The amount of the loan to petitioner and his associates was applied in cancellation and satisfaction of the note of the parties from whom the stock was being purchased and the stock was retained by the bank as collateral to the new loan.…
2Cases cited12 opinions
- Eckert v. BurnetSupreme Court of the United States · 1931
- Helvering v. PriceSupreme Court of the United States · 1940
- Burnet v. HuffSupreme Court of the United States · 1933
- Ferris v. CommissionerUnited States Board of Tax Appeals · 1938
- Jenkins v. BitgoodCourt of Appeals for the Second Circuit · 1939
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