Legal Opinion

Proctor v. Commissioner

United States Tax Court

Decided August 17, 1981No. Docket Nos. 11063-78, 11064-78, 11065-78UnpublishedCited by 11 opinions

Petitioners Joseph and Shirley Proctor owned all of the stock in petitioner Chattanooga Products while Joseph Proctor (Proctor) individually owned all of the stock in petitioner R & D. 1. Held, the Proctors failed to prove that unexplained bank deposits in 1972, 1973 and 1976 did not represent unreported income as determined by respondent. 2. Held, charitable contribution deductions under sec. 170(a)(1), I.R.C. 1954, for the Proctors' 1972, 1973 and 1976 tax years…

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Petitioners Joseph and Shirley Proctor owned all of the stock in petitioner Chattanooga Products while Joseph Proctor (Proctor) individually owned all of the stock in petitioner R & D. 1. Held, the Proctors failed to prove that unexplained bank deposits in 1972, 1973 and 1976 did not represent unreported income as determined by respondent. 2. Held, charitable contribution deductions under sec. 170(a)(1), I.R.C. 1954, for the Proctors' 1972, 1973 and 1976 tax years determined. 3. Held, payments by Proctor to Chattanooga Products and R & D during 1976 constituted interest deductible under sec.…

1Opinion of the Court

JOSEPH E. PROCTOR and SHIRLEY I. PROCTOR, ET AL., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Proctor v. Commissioner

Docket Nos. 11063-78, 11064-78, 11065-78.

United States Tax Court

T.C. Memo 1981-436; 1981 Tax Ct. Memo LEXIS 307; 42 T.C.M. (CCH) 725; T.C.M. (RIA) 81436;

August 17, 1981.

Petitioners Joseph and Shirley Proctor owned all of the stock in petitioner Chattanooga Products while Joseph Proctor (Proctor) individually owned all of the stock in petitioner R & D.

1. Held, the Proctors failed to prove that unexplained bank deposits in 1972, 1973 and 1976 did not represent…

2Cases cited93 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
  3. Gregory v. HelveringSupreme Court of the United States · 1935
  4. Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
  5. Knetsch v. United StatesSupreme Court of the United States · 1960

88 more not listed; retrieve them via the Exa API.

3Cited by11 opinions

  1. Banc One Corp. v. CommissionerUnited States Tax Court · 1985
  2. Solitron Devices, Inc. v. CommissionerUnited States Tax Court · 1983
  3. J.H. Rutter Rex Mfg. Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1988
  4. Decker v. CommissionerUnited States Tax Court · 1987
  5. Rosser v. Comm'rUnited States Tax Court · 2010

6 more not listed; retrieve them via the Exa API.

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