Burck v. Commissioner
United States Tax Court
Petitioner, a cash basis taxpayer, borrowed from a bank, late in the calendar year, amounts totaling $ 5,388,600. Of this amount $ 1 million was added to petitioner's bank account. On Dec. 30, 1969, 1 day after petitioner's receipt of the borrowed funds, pursuant to the negotiations culminating in the loan, the amount of $ 377,202, representing 1 year's interest on the loans, was debited to petitioner's bank account and transferred to the creditor bank.
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Petitioner, a cash basis taxpayer, borrowed from a bank, late in the calendar year, amounts totaling $ 5,388,600. Of this amount $ 1 million was added to petitioner's bank account. On Dec. 30, 1969, 1 day after petitioner's receipt of the borrowed funds, pursuant to the negotiations culminating in the loan, the amount of $ 377,202, representing 1 year's interest on the loans, was debited to petitioner's bank account and transferred to the creditor bank. Petitioners deducted this amount on their 1969 tax return under sec. 163(a). Respondent disallowed the deduction claiming the loan…
1Opinion of the Court
G. Douglas Burck and Marjorie W. Burck, Petitioners v. Commissioner of Internal Revenue, Respondent
Burck v. Commissioner
Docket No. 8909-72
United States Tax Court
63 T.C. 556; 1975 U.S. Tax Ct. LEXIS 190;
February 13, 1975, Filed
Decision will be entered under Rule 155.
Petitioner, a cash basis taxpayer, borrowed from a bank, late in the calendar year, amounts totaling $ 5,388,600. Of this amount $ 1 million was added to petitioner's bank account. On Dec. 30, 1969, 1 day after petitioner's receipt of the borrowed funds, pursuant to the negotiations culminating in the loan, the amount of $ 377,202,…
2Cases cited25 opinions
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Commissioner v. HansenSupreme Court of the United States · 1959
- Evans v. GoreSupreme Court of the United States · 1920
- Kapel Goldstein and Tillie Goldstein v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1966
- Stubbs, Overbeck & Associates, Inc. v. United StatesCourt of Appeals for the Fifth Circuit · 1971
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