Arrigoni v. Commissioner
United States Tax Court
Petitioners, as responsible officers of two corporations they owned which became insolvent, were assessed and paid both U.S. and Minnesota withholding taxes which were withheld by the corporations but not paid over and Minnesota sales taxes which were collected by one corporation but not paid over to the State, plus interest thereon. Held, petitioners are not entitled to deduct as bad debts the above taxes.
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Petitioners, as responsible officers of two corporations they owned which became insolvent, were assessed and paid both U.S. and Minnesota withholding taxes which were withheld by the corporations but not paid over and Minnesota sales taxes which were collected by one corporation but not paid over to the State, plus interest thereon. Held, petitioners are not entitled to deduct as bad debts the above taxes. Held, further, petitioners are not entitled to deduct the Minnesota withholding taxes withheld by the corporations but paid by petitioners under sec. 164(a)(3), I.R.C. 1954. Held, further,…
1Opinion of the Court
Drennen, Judge:
Respondent has determined a deficiency in the amount of $3,579.55 in petitioners’ 1974 income tax. After concessions, the issues presented for decision are:(1) Whether payment of certain taxes and satisfaction of a judgment by petitioners because of an employment relationship with their wholly owned corporations represent deductible business bad debts pursuant to section 166, I.R.C. 1954;1 and(2) If the payment by petitioners is not governed by section 166, whether any amounts paid by petitioners are deductible under section 163 as interest and/or under section 164 as taxes.
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2Cases cited21 opinions
- United States v. SoteloSupreme Court of the United States · 1978
- Edward J. Bloom v. United StatesCourt of Appeals for the Ninth Circuit · 1960
- Guardian Investment Corporation v. Robert L. Phinney, District Director of Internal RevenueCourt of Appeals for the Fifth Circuit · 1958
- Shiman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1932
- Rushing v. CommissionerUnited States Tax Court · 1972
16 more not listed; retrieve them via the Exa API.
3Cited by37 opinions
- Louis W. Levit, Trustee of V.N. Deprizio Construction Co. v. Ingersoll Rand Financial CorporationCourt of Appeals for the Seventh Circuit · 1989
- Medeiros v. CommissionerUnited States Tax Court · 1981
- Smith v. CommissionerUnited States Tax Court · 1985
- Kean v. CommissionerUnited States Tax Court · 1988
- Midkiff v. CommissionerUnited States Tax Court · 1991
32 more not listed; retrieve them via the Exa API.