Centel Communications Co. v. Commissioner
United States Tax Court
T Corp., struggling financially in its early years, sought additional capital through bank loans. As a condition for making the loans, the banks required D and G (individuals) and E Corp., three of T Corp.'s largest shareholders, to provide the banks with various personal guarantees, performance guarantees, and subordinations.
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T Corp., struggling financially in its early years, sought additional capital through bank loans. As a condition for making the loans, the banks required D and G (individuals) and E Corp., three of T Corp.'s largest shareholders, to provide the banks with various personal guarantees, performance guarantees, and subordinations. D, G, and E Corp. provided the guarantees and subordinations voluntarily and without the expectation of consideration or payment from T Corp. Several years later, in recognition of the increased risks the shareholders had assumed under the guarantees and subordinations,…
1Opinion of the Court
Parker, Judge:
In these consolidated cases, respondent determined deficiencies in petitioners’ Federal income tax as follows:
Petitioners TYE Amount
Centel Communications Co., 12/31/79 $ 34,101
(docket No. 7188-85) 3/24/80 542,756
Lloyd K. Davis and Estate of Patricia W. Davis, Deceased, Lloyd K. Davis and Edward H. White III, Independent Coexecutors (hereinafter individually and collectively referred to as Lloyd K. Davis, or Davis) (docket No. 12015-86) 12/31/80 443,812
Natalie T. Armstrong, formerly Natalie T. Grey, and Estate of Rex B. Grey, Deceased, Natalie Tandy Grey and Rex Oliver Grey,…
2Cases cited34 opinions
- United States v. American Trucking AssociationsSupreme Court of the United States · 1940
- 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
- Mayson Mfg. Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1949
29 more not listed; retrieve them via the Exa API.
3Cited by50 opinions
- Norfolk Southern Corp. v. CommissionerUnited States Tax Court · 1995
- Fort Howard Corp. v. CommissionerUnited States Tax Court · 1994
- Merkel v. CommissionerUnited States Tax Court · 1997
- Tele-Communications v. CommissionerUnited States Tax Court · 1990
- City of New York v. CommissionerUnited States Tax Court · 1994
45 more not listed; retrieve them via the Exa API.