Guren v. Commissioner
United States Tax Court
Held, the delivery by the pledgor to the pledgee of a demand promissory note does not constitute the "payment" of the pledge within the meaning of sec. 170(a)(1), notwithstanding the fact that the maker of the note had the resources to pay the note on demand and that the note might be enforceable under local law. Norman Petty, 40 T.C. 521 (1963), followed.
1Opinion of the Court
Sheldon B. Guren and Cynthia M. Guren, Petitioners v. Commissioner of Internal Revenue, Respondent
Guren v. Commissioner
Docket No. 7981-74
United States Tax Court
66 T.C. 118; 1976 U.S. Tax Ct. LEXIS 124;
April 19, 1976, Filed
Decision will be entered for the respondent.
Held, the delivery by the pledgor to the pledgee of a demand promissory note does not constitute the "payment" of the pledge within the meaning of sec. 170(a)(1), notwithstanding the fact that the maker of the note had the resources to pay the note on demand and that the note might be enforceable under local law. Norman Petty, 40…
2Cases cited12 opinions
- Eckert v. BurnetSupreme Court of the United States · 1931
- Helvering v. PriceSupreme Court of the United States · 1940
- Time Oil Company v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1958
- Sachs v. Commissioner of Internal Revenue. Slaymaker Lock Co. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1953
- Baltimore Dairy Lunch, Inc., a Corporation v. United StatesCourt of Appeals for the Eighth Circuit · 1956
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