Casa de La Jolla Park, Inc. v. Commissioner
United States Tax Court
C, a California corporation, was organized by M, a Canadian citizen and U.S. nonresident, to market time-share units in a 15-unit condominium. M held a promissory note from C which bore interest at 28 percent. B, a California bank, collected the proceeds from the time-share sales for C. R, a Canadian bank, had made substantial loans to M. As collateral for these loans, R held M's stock in BR, a Canadian public company of which M was president.
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C, a California corporation, was organized by M, a Canadian citizen and U.S. nonresident, to market time-share units in a 15-unit condominium. M held a promissory note from C which bore interest at 28 percent. B, a California bank, collected the proceeds from the time-share sales for C. R, a Canadian bank, had made substantial loans to M. As collateral for these loans, R held M's stock in BR, a Canadian public company of which M was president. When BR went into the Canadian equivalent of Chapter 11 bankruptcy reorganization, R sought further assurance of collection of M's debts. Accordingly,…
1Opinion of the Court
Casa De La Jolla Park, Inc., A California Corporation, Petitioner v. Commissioner of Internal Revenue, Respondent
Casa de La Jolla Park, Inc. v. Commissioner
Docket No. 28972-87
United States Tax Court
94 T.C. 384; 1990 U.S. Tax Ct. LEXIS 23; 94 T.C. No. 23;
March 13, 1990March 13, 1990, Filed
Decision will be entered for the respondent.
C, a California corporation, was organized by M, a Canadian citizen and U.S. nonresident, to market time-share units in a 15-unit condominium. M held a promissory note from C which bore interest at 28 percent. B, a California bank, collected the proceeds from the…
2Cases cited8 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Green v. CommissionerUnited States Tax Court · 1972
- Irving A. Adler v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1964
- Casa de La Jolla Park, Inc. v. CommissionerUnited States Tax Court · 1990
- Thomas W. Sowell and Lillian K. Sowell v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1962
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