Long v. Commissioner
United States Tax Court
Held, petitioner's motion to reconsider our opinion in Long v. Commissioner, 93 T.C. 5 (1989), is denied, as the doctrine of constructive payment is inapplicable to the satisfaction of an account receivable established pursuant to Rev. Proc. 65-17, 1965-1 C.B. 833.
1Opinion of the Court
SUPPLEMENTAL OPINION
WHITAKER, Judge:
We issued our opinion in Long v. Commissioner, 93 T.C. 5 (1989), in which we held that the portion of an account receivable established between related corporations pursuant to Rev. Proc. 65-17, 1965-1 C.B. 833, which was not offset by a preexisting account payable and not otherwise satisfied via the methods authorized in that revenue procedure constituted a constructive dividend to the common shareholder and contribution to the capital of the transferee corporation in accordance with the implementing closing agreement. Petitioner, who is the controlling…
2Cases cited3 opinions
- F. D. Bissett & Son, Inc. v. CommissionerUnited States Tax Court · 1971
- White v. CommissionerUnited States Tax Court · 1974
- Long v. CommissionerUnited States Tax Court · 1989
3Cited by1 opinion
- Long v. CommissionerUnited States Tax Court · 1989