Black v. Commissioner
United States Tax Court
Petitioners' testator prior to his death endorsed notes of X corporation payable to a bank. X had borrowed money from testator before this, giving him its notes. After testator's death X's net assets were only sufficient to pay 35 per cent of its general indebtedness.
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Petitioners' testator prior to his death endorsed notes of X corporation payable to a bank. X had borrowed money from testator before this, giving him its notes. After testator's death X's net assets were only sufficient to pay 35 per cent of its general indebtedness. Testator's estate, of which petitioners were residuary legatees, listed in its accounts and its estate tax return the amount payable on the endorsed notes at their face amount which was paid to the bank pursuant to claim filed, and listed as an asset the right to collect from X in the amount of 35 per cent of such amount.…
1Opinion of the Court
Anna R. Black, et al., 1 Petitioners, v. Commissioner of Internal Revenue, Respondent
Black v. Commissioner
Docket Nos. 79055, 79056, 79057, 79058
United States Tax Court
35 T.C. 398; 1960 U.S. Tax Ct. LEXIS 11;
December 9, 1960, Filed
Decisions will be entered for the respondent.
Petitioners' testator prior to his death endorsed notes of X corporation payable to a bank. X had borrowed money from testator before this, giving him its notes. After testator's death X's net assets were only sufficient to pay 35 per cent of its general indebtedness. Testator's estate, of which petitioners were residuary…
2Cases cited9 opinions
- Davenport v. CommissionerUnited States Tax Court · 1946
- Du Val v. CommissionerUnited States Tax Court · 1945
- Du Val's Estate v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1945
- Parrott v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1929
- Atwell v. CommissionerUnited States Tax Court · 1952
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