Funk v. Commissioner
United States Tax Court
1. Held, a note transferable on the books of the debtor corporation is a "security" (sec. 23(k)(3), I.R.C. 1939), and therefore the deduction for its worthlessness is limited by section 23(k)(2). Cf. Carl Oestreicher, 20 T.C. 12. 2. Held, loans aggregating $ 32,500 formed the basis for business bad debts; such loans to a publishing company controlled by petitioner were proximately related to his occupation as a professional writer. 3. Held, advances to the corporation,…
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1. Held, a note transferable on the books of the debtor corporation is a "security" (sec. 23(k)(3), I.R.C. 1939), and therefore the deduction for its worthlessness is limited by section 23(k)(2). Cf. Carl Oestreicher, 20 T.C. 12. 2. Held, loans aggregating $ 32,500 formed the basis for business bad debts; such loans to a publishing company controlled by petitioner were proximately related to his occupation as a professional writer. 3. Held, advances to the corporation, aggregating $ 55,000, at a time when it was in very poor financial condition were capital contributions and not true loans;…
1Opinion of the Court
Wilfred J. Funk and Eleanor M. Funk, Petitioners, v. Commissioner of Internal Revenue, Respondent
Funk v. Commissioner
Docket No. 70665
United States Tax Court
35 T.C. 42; 1960 U.S. Tax Ct. LEXIS 53;
October 13, 1960, Filed
Decision will be entered under Rule 50.
1. Held, a note transferable on the books of the debtor corporation is a "security" (sec. 23(k)(3), I.R.C. 1939), and therefore the deduction for its worthlessness is limited by section 23(k)(2). Cf. Carl Oestreicher, 20 T.C. 12.
2. Held, loans aggregating $ 32,500 formed the basis for business bad debts; such loans to a publishing company…
2Cases cited8 opinions
- H. Beale Rollins and Mary E. Rollins v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1960
- Rollins v. CommissionerUnited States Tax Court · 1959
- Bihlmaier v. CommissionerUnited States Tax Court · 1951
- Martin v. CommissionerUnited States Tax Court · 1955
- Gerard v. HelveringCourt of Appeals for the Second Circuit · 1941
3 more not listed; retrieve them via the Exa API.