Bullock's Dep't Store v. Comm'r
United States Tax Court
I. Held, on the facts, corporation's advances to its president and 99.9-percent shareholder were not loans, even though notes were executed, but were taxable dividends. II. Corporation's authorized bonuses for fiscal 1967 and 1968 to its president were neither paid nor credited on any corporate account within the 2-1/2 month period specified in sec. 267(a) (2) (A), I.R.C. 1954; consequently, held, claimed deductions for such bonuses were properly disallowed. III.
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I. Held, on the facts, corporation's advances to its president and 99.9-percent shareholder were not loans, even though notes were executed, but were taxable dividends. II. Corporation's authorized bonuses for fiscal 1967 and 1968 to its president were neither paid nor credited on any corporate account within the 2-1/2 month period specified in sec. 267(a) (2) (A), I.R.C. 1954; consequently, held, claimed deductions for such bonuses were properly disallowed. III. Corporation's president indicated that a similar bonus in fiscal 1969 was to be credited on his note to the corporation. Such…
1Opinion of the Court
BULLOCK'S DEPARTMENT STORE, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
WILLIAM G. and DORIS BULLOCK, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Bullock's Dep't Store v. Comm'r
Docket Nos. 7463-71, 7464-71.
United States Tax Court
T.C. Memo 1973-249; 1973 Tax Ct. Memo LEXIS 38; 32 T.C.M. (CCH) 1168; T.C.M. (RIA) 73249;
November 15, 1973, Filed
I. Held, on the facts, corporation's advances to its president and 99.9-percent shareholder were not loans, even though notes were executed, but were taxable dividends.
II. Corporation's authorized bonuses for fiscal 1967…
2Cases cited38 opinions
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Margit Sigray Bessenyey v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1967
- Clement L. Hirsch v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1963
- Electric & Neon, Inc. v. CommissionerUnited States Tax Court · 1971
- Ben Perlmutter and Bernice Perlmutter v. Commissioner of Internal Revenue, the Perlmutters, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1967
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