Legal Opinion

Bair v. Commissioner

United States Tax Court

Decided January 17, 1951No. Docket No. 23361Published

1. Petitioner Ruth V. Bair, one of the shareholders and bondholders of the F. & H. G. Corporation, was in 1938 indebted to F. & H. G. by reason of her previous borrowings from it. Interest at 6 per cent based on the average borrowings of all stockholders was adjusted among the accounts of the stockholders. In 1938, the corporation was dissolved.

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1. Petitioner Ruth V. Bair, one of the shareholders and bondholders of the F. & H. G. Corporation, was in 1938 indebted to F. & H. G. by reason of her previous borrowings from it. Interest at 6 per cent based on the average borrowings of all stockholders was adjusted among the accounts of the stockholders. In 1938, the corporation was dissolved. Petitioner Ruth V. Bair and the remaining stockholders conveyed all of the assets, including the claim against the former stockholders, to a revocable trust of which petitioner Ruth V. Bair is a grantor beneficiary. Under the terms of the trust…

1Opinion of the Court

Hilbert L. Bair and Ruth V. Bair, Petitioners, v. Commissioner of Internal Revenue, Respondent

Bair v. Commissioner

Docket No. 23361

United States Tax Court

16 T.C. 90; 1951 U.S. Tax Ct. LEXIS 313;

January 17, 1951, Promulgated

Decision will be entered for the respondent.

1. Petitioner Ruth V. Bair, one of the shareholders and bondholders of the F. & H. G. Corporation, was in 1938 indebted to F. & H. G. by reason of her previous borrowings from it. Interest at 6 per cent based on the average borrowings of all stockholders was adjusted among the accounts of the stockholders. In 1938, the corporation…

2Cases cited7 opinions

  1. Helvering v. CliffordSupreme Court of the United States · 1940
  2. Corliss v. BowersSupreme Court of the United States · 1930
  3. Schnitzer v. CommissionerUnited States Tax Court · 1949
  4. Dobkin v. CommissionerUnited States Tax Court · 1950
  5. Janeway v. CommissionerUnited States Tax Court · 1943

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