Legal Opinion

Casa de La Jolla Park, Inc. v. Commissioner

United States Tax Court

Decided March 13, 1990No. Docket No. 28972-87Published

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

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Green v. CommissionerUnited States Tax Court · 1972
  3. Irving A. Adler v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1964
  4. Casa de La Jolla Park, Inc. v. CommissionerUnited States Tax Court · 1990
  5. Thomas W. Sowell and Lillian K. Sowell v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1962

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