Weddle v. Commissioner
United States Tax Court
Held, when petitioner, president, general manager, and owner of 75 percent of the corporation's stock, paid a corporate debt pursuant to a prior personal guarantee of such debt, the corporation having liquidated, she incurred the loss on a nonbusiness bad debt inasmuch as such endorsement was not proximately related to a trade or business carried on by petitioner during that year.
1Opinion of the Court
FisheR, Judge:
Respondent determined a deficiency in petitioners’ income tax for the calendar year 1955 in the amount of $9,865.69.
One of the issues has been conceded. The only issue before us is whether petitioner may deduct a loss incurred during 1955 as a business or nonbusiness bad debt.
FINDINGS OF FACT.
Petitioners, George P. and Bertha R. (Terris) Weddle, are husband and wife and during the taxable year involved herein, 1955, lived in East Norwalk, Connecticut. Petitioners filed their joint Federal income tax return for the taxable year 1955 with the district director of internal revenue…
2Cases cited9 opinions
- Putnam v. CommissionerSupreme Court of the United States · 1956
- Burnet v. ClarkSupreme Court of the United States · 1932
- Dalton v. BowersSupreme Court of the United States · 1932
- John M. Trent and Lisa M. Trent v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1961
- Dallmeyer v. CommissionerUnited States Tax Court · 1950
4 more not listed; retrieve them via the Exa API.
3Cited by43 opinions
- George P. Weddle and Bertha R. (Terris) Weddle v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1963
- Smith v. CommissionerUnited States Tax Court · 1970
- Anderson v. CommissionerUnited States Tax Court · 1971
- Mitchell Kelly v. George Patterson, Director of Internal RevenueCourt of Appeals for the Fifth Circuit · 1964
- Gillespie v. CommissionerUnited States Tax Court · 1970
38 more not listed; retrieve them via the Exa API.