Schmidt v. Commissioner
United States Tax Court
Held, the balance in the amount of $ 27,445.71 in a reserve for bad debts account of petitioners' proprietorship was includable in petitioners' taxable income in 1959 when, in that year, the business of the proprietorship was transferred to a corporation in a transaction which qualified under section 351.
1Opinion of the Court
OPINION
Raum, Judge:
The sole issue before us is whether the balance in the proprietorship’s reserve for bad debts account in the amount of $27,445.71, as of June 30, 1959, was includable in petitioners’ taxable income in 1959 when, on June 30, 1959, the business of the proprietorship, including accounts receivable, was transferred to the corporation in a transaction which qualified for nomrecognition under section 351.2 The Government concedes that the transfer qualifies under section 351 and it does not challenge the amount in the reserve for bad debts as of June 30,1959, as an unreasonable…
2Cases cited8 opinions
- United States v. SanchezSupreme Court of the United States · 1950
- Geyer, Cornell & Newell, Inc. v. CommissionerUnited States Tax Court · 1946
- West Seattle National Bank of Seattle v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1961
- West Seattle Nat'l Bank v. CommissionerUnited States Tax Court · 1959
- Citizens Federal Savings and Loan Association of Cleveland v. United StatesCourt of Appeals for the Federal Circuit · 1961
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3Cited by15 opinions
- Bird Management, Inc. v. CommissionerUnited States Tax Court · 1967
- Estate of Heinz Schmidt, Deceased, and Charlotte Schmidt v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1966
- Argus, Inc. v. CommissionerUnited States Tax Court · 1965
- Schuster v. CommissionerUnited States Tax Court · 1968
- Hutton v. CommissionerUnited States Tax Court · 1969
10 more not listed; retrieve them via the Exa API.