Dembner v. Commissioner
United States Tax Court
The petitioners made loans, pledged stock as security for loans, and paid money for stock to be issued pursuant to various requests for funds mady by their son-in-law. The loans were not repaid, and the stock was not issued.
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The petitioners made loans, pledged stock as security for loans, and paid money for stock to be issued pursuant to various requests for funds mady by their son-in-law. The loans were not repaid, and the stock was not issued. Held, the funds and pledge were not obtained under circumstances constituting thefts under sec. 165(c), I.R.C. 1954; held further, one loan and part of the payment made to secure the return of the pledged stock resulted in worthless nonbusiness debts in 1968 under sec. 166(d), I.R.C. 1954.
1Opinion of the Court
SIDNEY DEMBNER and EVELYN DEMBNER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Dembner v. Commissioner
Docket No. 1359-72.
United States Tax Court
T.C. Memo 1974-180; 1974 Tax Ct. Memo LEXIS 139; 33 T.C.M. (CCH) 773; T.C.M. (RIA) 74180;
July 8, 1974, Filed.
The petitioners made loans, pledged stock as security for loans, and paid money for stock to be issued pursuant to various requests for funds mady by their son-in-law. The loans were not repaid, and the stock was not issued. Held, the funds and pledge were not obtained under circumstances constituting thefts under sec. 165(c),…
2Cases cited18 opinions
- Boagni v. CommissionerUnited States Tax Court · 1973
- Monteleone v. CommissionerUnited States Tax Court · 1960
- People v. . MillerNew York Court of Appeals · 1902
- People v. DioguardiNew York Court of Appeals · 1960
- Andrew v. CommissionerUnited States Tax Court · 1970
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