SCHMIT v. COMMISSIONER
United States Tax Court
In 1968 petitioner advanced a total of $25,000 to his brother in order to enable him to set up a leasing business. The transfer was evidenced by two promissory notes, one for $5,000 and one for $20,000. Held, a bona fide debt was created between petitioner and his brother in 1968. Held further, petitioner has not proven that the the debt became worthless in 1975, the year at issue.
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In 1968 petitioner advanced a total of $25,000 to his brother in order to enable him to set up a leasing business. The transfer was evidenced by two promissory notes, one for $5,000 and one for $20,000. Held, a bona fide debt was created between petitioner and his brother in 1968. Held further, petitioner has not proven that the the debt became worthless in 1975, the year at issue. Held further, because petitioner introduced no evidence in support of a claimed $83.42 medical expense deduction, it must be disallowed.
1Opinion of the Court
PAUL T. SCHMIT AND ROSEMARY SCHMIT, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
SCHMIT v. COMMISSIONER
Docket No. 1495-80.
United States Tax Court
T.C. Memo 1982-510; 1982 Tax Ct. Memo LEXIS 235; 44 T.C.M. (CCH) 1048; T.C.M. (RIA) 82510;
September 9, 1982.
In 1968 petitioner advanced a total of $25,000 to his brother in order to enable him to set up a leasing business. The transfer was evidenced by two promissory notes, one for $5,000 and one for $20,000. Held, a bona fide debt was created between petitioner and his brother in 1968. Held further, petitioner has not proven that the…
2Cases cited6 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Clark v. CommissionerUnited States Tax Court · 1952
- Clark v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1953
- Perry v. CommissionerUnited States Tax Court · 1954
- H. D. Lee Mercantile Co. v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1935
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