Legal Opinion

Gould v. Commissioner

United States Tax Court

Decided May 1, 1975No. Docket No. 1552-73PublishedCited by 42 opinions

A shareholder paid some of the debts of his corporation. Held, such payments were made to preserve his employment at another corporation and are deductible under sec. 162(a), I.R.C. 1954.

1Opinion of the Court

Simpson, Judge:

The Commissioner determined the following deficiencies in the petitioners’ Federal income taxes:

Year Deficiency

1965_$1,912.04

1968_ 3,143.48

The only issue for decision is whether certain payments which Mr. Gould made to creditors of his wholly owned corporation were, in effect, contributions to the capital of that corporation or were made to preserve his employment with another corporation.

FINDINGS OF FACT

Some of the facts have been stipulated, and those facts are so found.

The petitioners, James 0. Gould and Betty L. Gould, husband and wife, had their legal residence at…

2Cases cited15 opinions

  1. Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
  2. United States v. GeneresSupreme Court of the United States · 1972
  3. Millsap v. CommissionerUnited States Tax Court · 1966
  4. I. Hal Millsap, Jr., and Frances Millsap v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1968
  5. Lohrke v. CommissionerUnited States Tax Court · 1967

10 more not listed; retrieve them via the Exa API.

3Cited by42 opinions

  1. Markwardt v. CommissionerUnited States Tax Court · 1975
  2. Centel Communications Co. v. CommissionerUnited States Tax Court · 1989
  3. Gantner v. CommissionerUnited States Tax Court · 1988
  4. Spitz v. United StatesDistrict Court, E.D. Wisconsin · 1977
  5. Capital Video Corp. v. CommissionerCourt of Appeals for the First Circuit · 2002

37 more not listed; retrieve them via the Exa API.

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