Legal Opinion

Calcutt v. Commissioner

United States Tax Court

Decided July 13, 1988No. Docket No. 26418-86Published

In Calcutt v. Commissioner, 84 T.C. 716 (1985) (Calcutt I), petitioners, representing themselves without an attorney, failed to satisfy their burden of proving they were entitled to an increase of basis in the stock of a subchapter S corporation.

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In Calcutt v. Commissioner, 84 T.C. 716 (1985) (Calcutt I), petitioners, representing themselves without an attorney, failed to satisfy their burden of proving they were entitled to an increase of basis in the stock of a subchapter S corporation. In this case (Calcutt II), involving the same issue for a later year, petitioners, represented by an attorney, submitted additional evidence in the form of testimony not presented in Calcutt I. Held, the decision in Calcutt I, holding that corporate debts to third parties guaranteed by a shareholder do not lead to an increase in the shareholder's…

1Opinion of the Court

James K. Calcutt and June B. Calcutt Petitioners v. Commissioner of Internal Revenue, Respondent

Calcutt v. Commissioner

Docket No. 26418-86

United States Tax Court

91 T.C. 14; 1988 U.S. Tax Ct. LEXIS 86; 91 T.C. No. 2;

July 13, 1988; As amended July 14, 1988 July 13, 1988, Filed

Decision will be entered for the respondent.

In Calcutt v. Commissioner, 84 T.C. 716 (1985) (Calcutt I), petitioners, representing themselves without an attorney, failed to satisfy their burden of proving they were entitled to an increase of basis in the stock of a subchapter S corporation. In this case (Calcutt II),…

2Cases cited38 opinions

  1. Larry Bonner v. City of Prichard, AlabamaCourt of Appeals for the Eleventh Circuit · 1981
  2. Montana v. United StatesSupreme Court of the United States · 1979
  3. Commissioner v. SunnenSupreme Court of the United States · 1948
  4. Tait v. Western Maryland Railway Co.Supreme Court of the United States · 1933
  5. Fairmont Aluminum Company v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1955

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