Axelrod v. Commissioner
United States Tax Court
Petitioner and Cammer were partners in a cafe. Petitioner notified Cammer that unless Cammer purchased his interest he would bring an action for an accounting and dissolution of the partnership. Cammer borrowed funds from a finance company to purchase petitioner's interest in the partnership. Petitioner agreed to guarantee the loan with the finance company. Cammer defaulted on the loan and petitioner was required to pay the finance company the balance due on the loan.
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Petitioner and Cammer were partners in a cafe. Petitioner notified Cammer that unless Cammer purchased his interest he would bring an action for an accounting and dissolution of the partnership. Cammer borrowed funds from a finance company to purchase petitioner's interest in the partnership. Petitioner agreed to guarantee the loan with the finance company. Cammer defaulted on the loan and petitioner was required to pay the finance company the balance due on the loan. Petitioner deducted the amount paid as a bad debt under section 166(f), I.R.C. 1954. Held, the proceeds of the loan were not…
1Opinion of the Court
Max M. Axelrod, Petitioner, v. Commissioner of Internal Revenue, Respondent
Axelrod v. Commissioner
Docket No. 87288
United States Tax Court
37 T.C. 1053; 1962 U.S. Tax Ct. LEXIS 178;
March 8, 1962, Filed
Decision will be entered for the respondent.
Petitioner and Cammer were partners in a cafe. Petitioner notified Cammer that unless Cammer purchased his interest he would bring an action for an accounting and dissolution of the partnership. Cammer borrowed funds from a finance company to purchase petitioner's interest in the partnership. Petitioner agreed to guarantee the loan with the finance…
Also in this document: Dissent · Mulroney; Dissent · Fay.
2Cases cited4 opinions
- Putnam v. CommissionerSupreme Court of the United States · 1956
- DeGanay v. LedererSupreme Court of the United States · 1919
- Risko v. CommissionerUnited States Tax Court · 1956
- Axelrod v. CommissionerUnited States Tax Court · 1962