Imel v. Commissioner
United States Tax Court
1. Held, the $ 5,000 loss that petitioner sustained in 1968 when a debt owed him became worthless was a nonbusiness bad debt within the meaning of sec. 166(d), I.R.C. 1954. 2. Held, the $ 30,000 loss that petitioner sustained in 1968 in settlement of his liability as a guarantor of a $ 100,000 note is not deductible under sec. 166(f) because the proceeds of the note were not used in the trade or business of the borrower. 3. Held, the $ 30,000 loss that petitioner sustained…
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1. Held, the $ 5,000 loss that petitioner sustained in 1968 when a debt owed him became worthless was a nonbusiness bad debt within the meaning of sec. 166(d), I.R.C. 1954. 2. Held, the $ 30,000 loss that petitioner sustained in 1968 in settlement of his liability as a guarantor of a $ 100,000 note is not deductible under sec. 166(f) because the proceeds of the note were not used in the trade or business of the borrower. 3. Held, the $ 30,000 loss that petitioner sustained in 1968 in settlement of his liability as a guarantor resulted from the worthlessness of a debt so that sec. 166, I.R.C.…
1Opinion of the Court
Wiles, Judge:
Respondent has determined the following deficiencies in petitioners’ Federal income taxes:
Taxable year Deficiency
1965 _ $3, 364.00
1968 ___ 6, 006. 87
The issues remaining for decision are:
1. Whether a $5,000 loss incurred by petitioner in 1968 on the worthlessness of a debt is allowed as a deduction pursuant to section 166(a),I.R.C. 1954.1
2. Whether the proceeds of a $100,000 loan were used in the trade or business of the borrower so that a $30,000 payment made by petitioner in 1968 in settlement of his liability as a guarantor on such loan is deductible under section 166 (f).
3.…
2Cases cited18 opinions
- Whipple v. CommissionerSupreme Court of the United States · 1963
- Putnam v. CommissionerSupreme Court of the United States · 1956
- United States v. GeneresSupreme Court of the United States · 1972
- H. Beale Rollins and Mary E. Rollins v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1960
- Rushing v. CommissionerUnited States Tax Court · 1972
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3Cited by46 opinions
- Shinefeld v. CommissionerUnited States Tax Court · 1976
- Benak v. CommissionerUnited States Tax Court · 1981
- Efco Tool Co. v. CommissionerUnited States Tax Court · 1983
- Rutter v. Comm'rUnited States Tax Court · 2017
- Betts v. CommissionerUnited States Tax Court · 1974
41 more not listed; retrieve them via the Exa API.