Roussel v. Commissioner
United States Tax Court
In 1954, petitioner conducted a coffee brokerage business in his individual capacity, which business consisted mainly of acting as a local agent for Hard & Rand, Inc., a coffee importer. He also was manager and major shareholder of a corporation bearing his name which also bought and sold coffee. Both businesses were conducted from the same office, but separate books were maintained.
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In 1954, petitioner conducted a coffee brokerage business in his individual capacity, which business consisted mainly of acting as a local agent for Hard & Rand, Inc., a coffee importer. He also was manager and major shareholder of a corporation bearing his name which also bought and sold coffee. Both businesses were conducted from the same office, but separate books were maintained. In the latter part of 1954 the corporation, though solvent, was in need of cash and Hard & Rand, Inc., voluntarily loaned $ 75,000 to the corporation. Petitioner personally endorsed the note evidencing said loan…
1Opinion of the Court
Fisher, Judge:
Respondent determined deficiencies in income tax of the petitioners as follows:
Year Amount
1953 -$7, 639. 90
1954 _ 13,036.24
1955 - 8,099.77
1956 - 1, 574.55
It is stipulated that the deficiencies for the years 1953, 1954, and 1956, arose out of the disallowance of a claimed operating loss for 1955 carried back 2 years and forward 1 year, and that all of the deficiencies depend upon the correct amount of operating loss, if any, for the year 1955.
The sole issue for our determination is whether the amount paid by petitioner in 1955 on behalf of the corporation as required by his…
2Cases cited14 opinions
- Putnam v. CommissionerSupreme Court of the United States · 1956
- Snow v. CommissionerUnited States Tax Court · 1958
- L. Heller & Son, Inc. v. CommissionerUnited States Tax Court · 1949
- Trinco Industries, Inc. v. CommissionerUnited States Tax Court · 1954
- Sherman v. CommissionerUnited States Tax Court · 1952
9 more not listed; retrieve them via the Exa API.
3Cited by35 opinions
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- Cimarron Trust Estate v. CommissionerUnited States Tax Court · 1972
- Southeastern Aviation Underwriters, Inc. v. CommissionerUnited States Tax Court · 1966
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