Bair v. Commissioner
United States Tax Court
1. Petitioner Ruth V. Bair, one of the shareholders and bondholders of the F. & H. G. Corporation, was in 1938 indebted to F. & H. G. by reason of her previous borrowings from it. Interest at 6 per cent based on the average borrowings of all stockholders was adjusted among the accounts of the stockholders. In 1938, the corporation was dissolved.
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1. Petitioner Ruth V. Bair, one of the shareholders and bondholders of the F. & H. G. Corporation, was in 1938 indebted to F. & H. G. by reason of her previous borrowings from it. Interest at 6 per cent based on the average borrowings of all stockholders was adjusted among the accounts of the stockholders. In 1938, the corporation was dissolved. Petitioner Ruth V. Bair and the remaining stockholders conveyed all of the assets, including the claim against the former stockholders, to a revocable trust of which petitioner Ruth V. Bair is a grantor beneficiary. Under the terms of the trust…
1Opinion of the Court
OPINION.
Black, Judge:
Interest issue. — Petitioner Ruth V. Bair is one of the grantor beneficiaries of the Goldsmith Trust, conceded to be & revocable trust, and petitioners have conceded the correctness of respondent’s allegations in his amended answer relating to the portion of the trust income taxable to petitioners. However, respondent in the deficiency notice increased petitioners’ net income by the amount of $1,109.14 which represents interest credited to the account of petitioner Ruth V. Bair in accordance with paragraph III of the trust indenture, and petitioners contest this…
2Cases cited6 opinions
- Helvering v. CliffordSupreme Court of the United States · 1940
- Corliss v. BowersSupreme Court of the United States · 1930
- Schnitzer v. CommissionerUnited States Tax Court · 1949
- Dobkin v. CommissionerUnited States Tax Court · 1950
- Janeway v. CommissionerUnited States Tax Court · 1943
1 more not listed; retrieve them via the Exa API.
3Cited by5 opinions
- Earle, Collector of Internal Revenue v. W. J. Jones & Son, Inc. United States v. W. J. Jones & Son, IncCourt of Appeals for the Ninth Circuit · 1952
- Royalty Service Corporation v. United StatesDistrict Court, D. Montana · 1959
- Bair v. CommissionerUnited States Tax Court · 1951
- Bair v. United StatesUnited States Court of Claims · 1962
- Harkins Bowling, Inc. v. KnoxDistrict Court, D. Minnesota · 1958