Legal Opinion
A. J. Whipple and Mildred Whipple v. Commissioner of Internal Revenue
Court of Appeals for the Fifth Circuit
Decided May 11, 1962No. 18963_1PublishedCited by 7 opinions
1Opinion of the Court
TUTTLE, Chief Judge.
The taxpayer-petitioners here complain 0f the decision of the Tax Court which held that the taxpayers’ advances to the corporation, in which the husband held a majority interest, represented, within the meaning of Section 23 (k) of the 1939 Internal Revenue Code, 26 U.S.C.A. § 23 (k) a non-business rather than a business bad debt, when these advances became worthless upon the insolvency of the corporation. So far as is significant here a non-business bad debt is defined in the statute as one “other than a debt ^he joss from the worthlessness of which jg jncurre(j jn the…
2Cases cited6 opinions
- Higgins v. CommissionerSupreme Court of the United States · 1941
- Burnet v. ClarkSupreme Court of the United States · 1932
- Vincent C. Giblin v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1955
- S. D. Ferguson v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1958
- Merriman H. Holtz and Helene Tyroll Holtz v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1958
1 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- H. H. Bodzy and Marjorie Bodzy v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1963
- Richard E. Wiles, Jr., and Constance K. Wiles v. United States of America, Brooks C. Noah and Mary Ann Noah v. United StatesCourt of Appeals for the Tenth Circuit · 1962
- United States v. Sylvan M. Byck and Beatrice ByckCourt of Appeals for the Fifth Circuit · 1963
- Mitchell Kelly v. George Patterson, Director of Internal RevenueCourt of Appeals for the Fifth Circuit · 1964
- Plante v. United StatesDistrict Court, D. New Hampshire · 1963
2 more not listed; retrieve them via the Exa API.