Holbrook v. Commissioner
United States Tax Court
In an ABC transaction, petitioner (B) furnished a guaranty of a note issued by C to a bank which lent C funds in order to purchase a reserved production payment from A. The guaranty did not extend to C. Held, petitioner had an economic interest in the production payment, with the result that the income attributable thereto was taxable to him.
1Opinion of the Court
Finley W. Holbrook and Faith Holbrook, Petitioners v. Commissioner of Internal Revenue, Respondent
Holbrook v. Commissioner
Docket No. 2475-66
United States Tax Court
54 T.C. 1617; 1970 U.S. Tax Ct. LEXIS 78; 37 Oil & Gas Rep. 489;
August 20, 1970, Filed
Decision will be entered for the respondent.
In an ABC transaction, petitioner (B) furnished a guaranty of a note issued by C to a bank which lent C funds in order to purchase a reserved production payment from A. The guaranty did not extend to C. Held, petitioner had an economic interest in the production payment, with the result that the income…
2Cases cited14 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Commissioner v. Estate of NoelSupreme Court of the United States · 1965
- United States v. Rhode Island Hospital Trust CompanyCourt of Appeals for the First Circuit · 1966
- United States v. W. H. CockeCourt of Appeals for the Fifth Circuit · 1968
- Olin Bryant and Vanell Bryant v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1968
9 more not listed; retrieve them via the Exa API.