Brenner v. Commissioner
United States Tax Court
During 1963, Brenner, an account executive in a stock brokerage firm, Ira Haupt, borrowed funds (about $ 180,000) from certain customers to enable him to acquire a 1-percent partnership interest in the firm. Shortly thereafter Ira Haupt failed, and as a general partner petitioner became jointly and severally liable for its debts.
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During 1963, Brenner, an account executive in a stock brokerage firm, Ira Haupt, borrowed funds (about $ 180,000) from certain customers to enable him to acquire a 1-percent partnership interest in the firm. Shortly thereafter Ira Haupt failed, and as a general partner petitioner became jointly and severally liable for its debts. He obtained another stock brokerage job and orally promised the senior partner of that firm to repay the customers who had loaned him the funds to acquire his partnership interest in Ira Haupt. He was allowed a net operating loss of $ 559,468.11 for 1963, stemming…
1Opinion of the Court
Howard M. Brenner and Peggy Brenner, Petitioners v. Commissioner of Internal Revenue, Respondent
Brenner v. Commissioner
Docket No. 3004-72
United States Tax Court
62 T.C. 878; 1974 U.S. Tax Ct. LEXIS 39; 62 T.C. No. 93;
September 30, 1974, Filed
Decision will be entered under Rule 155.
During 1963, Brenner, an account executive in a stock brokerage firm, Ira Haupt, borrowed funds (about $ 180,000) from certain customers to enable him to acquire a 1-percent partnership interest in the firm. Shortly thereafter Ira Haupt failed, and as a general partner petitioner became jointly and severally liable…
2Cases cited21 opinions
- United States v. Skelly Oil Co.Supreme Court of the United States · 1969
- Charles Ilfeld Co. v. HernandezSupreme Court of the United States · 1934
- Zavelo v. ReevesSupreme Court of the United States · 1913
- Lohrke v. CommissionerUnited States Tax Court · 1967
- Dinardo v. CommissionerUnited States Tax Court · 1954
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