Towers v. Commissioner
United States Tax Court
1. Petitioners engaged in a number of promotional business ventures up to 1939. From 1939 through 1947, petitioners' main activities (other than the practice of law, in which three of them were engaged) were in the capacity of stockholders, officers, directors, and employees, first of Aircraft and Arms Consultants, Inc., then Rumsey Manufacturing Co. (Balch-Morris), and finally Rumsey Products Co. Several of petitioners made loans to Rumsey Products in 1947 by giving the…
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1. Petitioners engaged in a number of promotional business ventures up to 1939. From 1939 through 1947, petitioners' main activities (other than the practice of law, in which three of them were engaged) were in the capacity of stockholders, officers, directors, and employees, first of Aircraft and Arms Consultants, Inc., then Rumsey Manufacturing Co. (Balch-Morris), and finally Rumsey Products Co. Several of petitioners made loans to Rumsey Products in 1947 by giving the company their personal checks and concurrently receiving in return a check of the corporation in the same amount and…
1Opinion of the Court
FisheR, Judge:
The respondent determined deficiencies in the Federal income taxes of petitioners as follows:
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The issues presented for our consideration are:(1) Whether certain unpaid loans made by several of petitioners in 1947 to Rumsey Products, Inc., with which they were variously associated as stockholders, employees, officers, and directors were business bad debts arising from a business of promoting, organizing, managing, and financing business enterprises, or were nonbusiness bad debts.(2) Whether losses sustained by several of the petitioners from advances to a so-called…
2Cases cited30 opinions
- Spring City Foundry Co. v. CommissionerSupreme Court of the United States · 1934
- Burnet v. ClarkSupreme Court of the United States · 1932
- Lewellyn v. Electric Reduction Co.Supreme Court of the United States · 1927
- Fairbanks v. United StatesSupreme Court of the United States · 1939
- Flanagan v. HelveringCourt of Appeals for the D.C. Circuit · 1940
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3Cited by90 opinions
- Millsap v. CommissionerUnited States Tax Court · 1966
- Theodore C. Bonney v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1957
- Martin v. CommissionerUnited States Tax Court · 1955
- Romine v. Comm'rUnited States Tax Court · 1956
- Rafter v. CommissionerUnited States Tax Court · 1973
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