Estate of Johnson v. Commissioner
United States Tax Court
1. Decedent guaranteed a loan from a bank to a corporation of which he was majority shareholder and assigned insurance policies on his life as collateral.
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1. Decedent guaranteed a loan from a bank to a corporation of which he was majority shareholder and assigned insurance policies on his life as collateral. Decedent died before the notes were repaid; the bank collected $ 4.2 million in insurance proceeds, and assigned the notes to P (decedent's estate). P and R entered into a closing agreement pursuant to sec. 7121, I.R.C. 1954, setting the value for estate tax purposes and the unadjusted basis for income tax purposes of P's subordinated rights in the notes as of the date of decedent's death at $ 600,000. The notes were repaid in full in 1980…
1Opinion of the Court
WILLIAMS, Judge-.
The Commissioner determined deficiencies in petitioner’s Federal income tax for the taxable years 1980 and 1981 as follows:
Year Deficiency
1980 . $269,963
1981 . 109,165
Petitioner claims an overpayment in Federal income tax in the amounts of $712,045 for 1980 and $93,198 for 1981. The issues for decision are (1) whether petitioner correctly reported capital gains realized from its collection on certain notes in 1980 and 1981; and (2) whether petitioner properly deducted as income distributions in 1980 and 1981 amounts credited to the Estate of Willard T.C. Johnson.
FINDINGS OF…
2Cases cited13 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Achiro v. CommissionerUnited States Tax Court · 1981
- Farrier v. CommissionerUnited States Tax Court · 1950
- Commissioner of Internal Revenue v. StearnsCourt of Appeals for the Second Circuit · 1933
- Estate of O'Connor v. CommissionerUnited States Tax Court · 1977
8 more not listed; retrieve them via the Exa API.
3Cited by11 opinions
- Zaentz v. CommissionerUnited States Tax Court · 1988
- Jonathan B. Geftman v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1998
- Long v. CommissionerUnited States Tax Court · 1989
- NADLER v. COMMISSIONERUnited States Tax Court · 1992
- Davis v. CommissionerUnited States Tax Court · 1989
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