Stoody v. Commissioner
United States Tax Court
Petitioner guaranteed the obligations of a corporation organized to operate a retail discount store. Shortly after the store opened, the business failed and the store closed. Lawsuits were filed against petitioner as guarantor of the corporation's debts. Petitioner settled the lawsuits filed against him. Held, the payments made in settlement of the lawsuits filed against petitioner are deductible only as nonbusiness bad debts under sec. 166(d).
1Opinion of the Court
Irwin, Judge:
Respondent determined deficiencies in petitioners’ Federal income tax for the calendar years 1968 and 1969 in the amounts of $4,568 and $3,716, respectively. The sole issue raised in this litigation is whether payments made by Winston Stoody under a settlement agreement entered into to settle a lawsuit are deductible in full in the years of payment or are subject to the capital loss limitations of section 1211 of the Internal Revenue Code of 1954.1
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. The stipulation of facts, together with the exhibits attached…
2Cases cited25 opinions
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- Putnam v. CommissionerSupreme Court of the United States · 1956
- United States v. GeneresSupreme Court of the United States · 1972
20 more not listed; retrieve them via the Exa API.
3Cited by29 opinions
- Redwood Empire Sav. & Loan Asso. v. CommissionerUnited States Tax Court · 1977
- Stoody v. CommissionerUnited States Tax Court · 1977
- Entwicklungs und Finanzierungs A.G. v. CommissionerUnited States Tax Court · 1977
- Black Gold Energy Corp. v. CommissionerUnited States Tax Court · 1992
- United States v. YoungDistrict Court, N.D. Oklahoma · 1984
24 more not listed; retrieve them via the Exa API.