Legal Opinion

Estate of Byers v. Commissioner

United States Tax Court

Decided January 31, 1972No. Docket No. 1693-68Published

Held, losses from the worthlessness of interest-free advances made by major stockholder and officer of a corporation to or on behalf of a customer of the corporation are deductible as nonbusiness bad debts.

1Opinion of the Court

Estate of Martha M. Byers, Deceased, Frank M. Byers, Executor, and Frank M. Byers, Sr., Petitioners v. Commissioner of Internal Revenue, Respondent

Estate of Byers v. Commissioner

Docket No. 1693-68

United States Tax Court

57 T.C. 568; 1972 U.S. Tax Ct. LEXIS 189;

January 31, 1972, Filed

Decision will be entered for the respondent.

Held, losses from the worthlessness of interest-free advances made by major stockholder and officer of a corporation to or on behalf of a customer of the corporation are deductible as nonbusiness bad debts.

H. Thompson Nicholas, Jr., for the petitioners.

Robert A. Roberts,…

2Cases cited26 opinions

  1. Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
  2. Higgins v. CommissionerSupreme Court of the United States · 1941
  3. Whipple v. CommissionerSupreme Court of the United States · 1963
  4. Putnam v. CommissionerSupreme Court of the United States · 1956
  5. Burnet v. ClarkSupreme Court of the United States · 1932

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