Rollins v. Commissioner
United States Tax Court
1. Held, petitioner was not in the separate business of promoting, financing, managing, and organizing businesses, or of lending money in 1952 and 1953, and certain losses sustained by petitioner in those years are not deductible as business bad debts under section 23(k)(1), I.R.C. 1939. 2. Held, advances made by petitioner to Associated Buck Canning Machines, Inc., did not become worthless in the year 1953.
1Opinion of the Court
Dkennen, Judge:
Respondent has determined deficiencies in petitioners’ income tax for the years 1952, 1953, and 1954 in the amounts of $11,362.24, $34,854.04, and $6,538.84* respectively.
The sole issue in respect to 1952 is whether the loss suffered from the worthlessness of a loan of $20,000 made to Manufacturers Research Corporation should be treated as a business or nonbusiness bad debt. In respect to 1953, the questions are: (1) Whether losses resulting from advances totaling $111,969.60 to Associated Buck Canning Machines, Inc., were sustained during 1953; (2) if so, whether such advances…
2Cases cited21 opinions
- Higgins v. CommissionerSupreme Court of the United States · 1941
- Burnet v. ClarkSupreme Court of the United States · 1932
- Benjamin D. And Madeline Prentice Gilbert, on Review v. Commissioner of Internal Revenue, on ReviewCourt of Appeals for the Second Circuit · 1959
- Campbell v. CommissionerUnited States Tax Court · 1948
- Boissevain v. CommissionerUnited States Tax Court · 1951
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3Cited by56 opinions
- Millsap v. CommissionerUnited States Tax Court · 1966
- Demes v. United StatesUnited States Court of Federal Claims · 2002
- Trent v. CommissionerUnited States Tax Court · 1960
- Pachella v. CommissionerUnited States Tax Court · 1961
- Deely v. CommissionerUnited States Tax Court · 1980
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