Proesel v. Commissioner
United States Tax Court
In 1971, P became a partner in C, and C became a partner in B. Previously, B had contracted with G to produce a motion picture for G. B's right to payment under such contract was not contingent upon G's commercial exploitation of the picture. B produced the picture pursuant to such contract.
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In 1971, P became a partner in C, and C became a partner in B. Previously, B had contracted with G to produce a motion picture for G. B's right to payment under such contract was not contingent upon G's commercial exploitation of the picture. B produced the picture pursuant to such contract. By the end of 1972, efforts to find a distributor for the picture had proved unsuccessful, and G was in default on its contract obligation to B. Held, P is not entitled to either a business loss or a bad debt deduction in 1972 because he failed to prove that the right to receive payments from G became…
1Opinion of the Court
Simpson, Judge:
The Commissioner determined deficiencies in the petitioners’ Federal income taxes of $21,661.84 for 1971 and $6,237.09 for 1972. After concessions by the petitioners, the sole issue for decision is whether the petitioners are entitled to either a business loss or a bad debt deduction in 1972 with respect to Mr. Proesel’s interest in a motion picture production service partnership.
FINDINGS OF FACT
Some of the facts have been stipulated, and those facts are so found.
The petitioners, James V. and Rosemary K. Proesel, husband and wife, resided in Lincolnwood, Ill., at the time they…
2Cases cited25 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
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- United States v. S. S. White Dental Manufacturing Co.Supreme Court of the United States · 1927
- Boehm v. CommissionerSupreme Court of the United States · 1945
- Putnam v. CommissionerSupreme Court of the United States · 1956
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