Bratton v. Commissioner
United States Tax Court
The stockholders of a close corporation, indebted to them for compensation of $ 166,000, decided to liquidate. In December 1952, certain assets were sold for the vendees' notes in the amount of $ 205,000, plus a purported assumption of the corporation's indebtedness to its stockholders, it being provided that all payments on the notes were to be credited on that indebtedness.
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The stockholders of a close corporation, indebted to them for compensation of $ 166,000, decided to liquidate. In December 1952, certain assets were sold for the vendees' notes in the amount of $ 205,000, plus a purported assumption of the corporation's indebtedness to its stockholders, it being provided that all payments on the notes were to be credited on that indebtedness. The corporation pledged the notes with a bank to secure its stockholder indebtedness, the bank to collect the proceeds thereon for the stockholders' account, with the right to defer payment of any amount collected in…
1Opinion of the Court
Tietjens, Judge:
These consolidated proceedings involve deficiencies in income tax and additions thereto in the amounts and for the years as set forth below:
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By amended answer respondent, pleading in the alternative, claimed increased deficiencies in each of the above proceedings and an increased addition to tax under section 294(d) (2) in Docket No. 60113 for 1952; and further, by way of a second alternative, claimed increased deficiencies in each of the above proceedings and an increased addition to tax under section 294(d) (2) in Docket No. 60092 for 1953.
The issue for decision…
2Cases cited8 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Higgins v. SmithSupreme Court of the United States · 1940
- Benjamin D. And Madeline Prentice Gilbert v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1957
- Diescher v. CommissionerUnited States Board of Tax Appeals · 1937
3 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Braddock Land Co. v. CommissionerUnited States Tax Court · 1980
- Estate of Louis Kamm, Deceased, and Emily E. Kamm, Surviving Wife, Also Known as Edythe Emily Kamm v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1965
- Crown v. CommissionerUnited States Tax Court · 1972
- Estate of Kamm v. CommissionerUnited States Tax Court · 1963
- Braddock Land Co. v. CommissionerUnited States Tax Court · 1980
2 more not listed; retrieve them via the Exa API.