First Nat'l Co. v. Commissioner
United States Tax Court
In July 1951, G. L. Comer, a director and vice president of the petitioner, had possession of eight notes which the petitioner had issued to five banks and a trust company during 1930 and 1931 and one note which the petitioner had issued to Comer and two others in 1943. The total outstanding balance on the notes was $ 1,838,299.10. On or about July 23, 1951, Comer gave the nine notes to the Church of Christ Foundation, Inc., a tax exempt organization.
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In July 1951, G. L. Comer, a director and vice president of the petitioner, had possession of eight notes which the petitioner had issued to five banks and a trust company during 1930 and 1931 and one note which the petitioner had issued to Comer and two others in 1943. The total outstanding balance on the notes was $ 1,838,299.10. On or about July 23, 1951, Comer gave the nine notes to the Church of Christ Foundation, Inc., a tax exempt organization. On August 1, 1951, the petitioner issued its unsecured, demand promissory note for $ 1,838,299.10 to the Foundation which at that time…
1Opinion of the Court
Withex, Judge:
Deficiencies in income tax for the taxable years 1951, 1952, and 1953 have been determined by the Commissioner against petitioner in the respective amounts of $42,381.19, $5,742.79, and $6,597.97. The only question presented for determination is whether respondent erred in disallowing deductions taken as interest upon a demand promissory note issued by petitioner to a tax exempt organization. All other issues raised by the pleadings have been disposed of by stipulation of the parties. The taxable year 1954 also is involved because of a net operating loss for which petitioner has…
2Cases cited10 opinions
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