Prizant v. Commissioner
United States Tax Court
(1) DP sold certain stock in 1963 in order to make a loan to a corporation. She received a noninterest-bearing demand note and an agreement in which the corporation acknowledged her loan and promised to pay any additional amounts necessary for her to repurchase the number of shares she sold in order to make the loan. Held, DP realized a capital gain in 1964 when, in accordance with the agreement, she received payments in excess of the amount loaned by her.
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(1) DP sold certain stock in 1963 in order to make a loan to a corporation. She received a noninterest-bearing demand note and an agreement in which the corporation acknowledged her loan and promised to pay any additional amounts necessary for her to repurchase the number of shares she sold in order to make the loan. Held, DP realized a capital gain in 1964 when, in accordance with the agreement, she received payments in excess of the amount loaned by her. (2) JP was a member of a partnership, which in 1958 transferred substantially all of its assets and its business activity to a…
1Opinion of the Court
Jerome Prizant and Doris Prizant v. Commissioner.
Prizant v. Commissioner
Docket No. 3681-67.
United States Tax Court
T.C. Memo 1971-196; 1971 Tax Ct. Memo LEXIS 136; 30 T.C.M. (CCH) 817; T.C.M. (RIA) 71196;
August 10, 1971, Filed(1) DP sold certain stock in 1963 in order to make a loan to a corporation. She received a noninterest-bearing demand note and an agreement in which the corporation acknowledged her loan and promised to pay any additional amounts necessary for her to repurchase the number of shares she sold in order to make the loan. Held, DP realized a capital gain in 1964 when, in…
2Cases cited28 opinions
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Commissioner v. TowerSupreme Court of the United States · 1946
- Old Colony Railroad v. CommissionerSupreme Court of the United States · 1932
- Burnet v. LoganSupreme Court of the United States · 1931
- Arrowsmith v. CommissionerSupreme Court of the United States · 1952
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