Legal Opinion

Loeb v. Commissioner

United States Tax Court

Decided November 21, 1945No. Docket No. 3695Published

X was indebted to Y in the sum of approximately $ 750,000. He owned stock of a corporation which was pledged to a broker to secure his account in the sum of approximately $ 250,000 and the account of a business associate. In 1935 X and Y entered into a contract whereby Y was given a lien upon this stock and was entitled to the payment of a certain share of the dividends thereon for 10 years.

Read the full summary

X was indebted to Y in the sum of approximately $ 750,000. He owned stock of a corporation which was pledged to a broker to secure his account in the sum of approximately $ 250,000 and the account of a business associate. In 1935 X and Y entered into a contract whereby Y was given a lien upon this stock and was entitled to the payment of a certain share of the dividends thereon for 10 years. Y also received certain choses in action from X which, when credited on his indebtedness, reduced it to approximately $ 500,000. If at the end of 10 years this latter amount had not been paid by the…

1Opinion of the Court

Herbert A. Loeb, Petitioner, v. Commissioner of Internal Revenue, Respondent

Loeb v. Commissioner

Docket No. 3695

United States Tax Court

5 T.C. 1072; 1945 U.S. Tax Ct. LEXIS 41; T.C.M. (RIA) 45306;

November 21, 1945, Promulgated 1

Decision will be entered under Rule 50.

X was indebted to Y in the sum of approximately $ 750,000. He owned stock of a corporation which was pledged to a broker to secure his account in the sum of approximately $ 250,000 and the account of a business associate. In 1935 X and Y entered into a contract whereby Y was given a lien upon this stock and was entitled to the…

2Cases cited2 opinions

  1. Driscoll v. CommissionerUnited States Tax Court · 1944
  2. Loeb v. CommissionerUnited States Tax Court · 1945

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API