Couchman v. Commissioner
United States Board of Tax Appeals
Petitioner borrowed money from his father's estate with the consent of his brother, who imposed a condition that he share in any profit from the ownership of the stock exchange seat which petitioner bought with the borrowed money. When the value of the seat increased substantially petitioner acknowledged in writing his indebtedness to the brother in an amount equal to one half the increase in the value of the seat.
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Petitioner borrowed money from his father's estate with the consent of his brother, who imposed a condition that he share in any profit from the ownership of the stock exchange seat which petitioner bought with the borrowed money. When the value of the seat increased substantially petitioner acknowledged in writing his indebtedness to the brother in an amount equal to one half the increase in the value of the seat. Petitioner thereafter paid interest on the indebtedness to his brother and curtailed the principal. Held, the interest so paid is deductible.
1Opinion of the Court
WILLIAM VENNING COUCHMAN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Couchman v. Commissioner
Docket Nos. 67729, 70957.
United States Board of Tax Appeals
30 B.T.A. 118; 1934 BTA LEXIS 1364;
March 20, 1934, Promulgated
Petitioner borrowed money from his father's estate with the consent of his brother, who imposed a condition that he share in any profit from the ownership of the stock exchange seat which petitioner bought with the borrowed money. When the value of the seat increased substantially petitioner acknowledged in writing his indebtedness to the brother in an amount equal…
2Cases cited1 opinion
- Couchman v. CommissionerUnited States Board of Tax Appeals · 1934