Heman v. Commissioner
United States Tax Court
Decedent and his brother John owned all the common and preferred shares of Trinidad Asphalt Manufacturing Company, with the exception of 3 qualifying shares of common stock. Both were indebted to Trinidad on open account for differing amounts.
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Decedent and his brother John owned all the common and preferred shares of Trinidad Asphalt Manufacturing Company, with the exception of 3 qualifying shares of common stock. Both were indebted to Trinidad on open account for differing amounts. Pursuant to agreements between Trinidad and decedent's estate and between Trinidad and John, and following the allowance by the Probate Court of Trinidad's claim against the estate, Trinidad canceled all of decedent's and a portion of John's indebtedness upon their surrender of 250 shares of preferred stock each. John and the estate each retained their…
1Opinion of the Court
Beuce, Judge:
These consolidated proceedings involve deficiencies in income tax and additions thereto in tbe amounts and for tbe years as set forth below:
Genevra Heman, Docket No. 63857
Addition to tax, Addition to tax,
Tear Deficiency sec. 294(d) (1) (A) sec. 294(d) (2)
1950_ $1,928. 85 $195.12 $130.07
Shelbt L. Heman Trust u/w Genevra Heman and Mercantile Trust Co., Trustees, Docket No. 63899
Taxable period Addition to tax, Deficiency see. 291(a)
June 27,1950 to Dec. 31,1950. $5, 361.06 $1, 340.27
The issues for decision are: (1) Whether the cancellation of decedent stockholder’s debt upon the…
2Cases cited26 opinions
- Wall v. United StatesCourt of Appeals for the Fourth Circuit · 1947
- Fuller v. CommissionerUnited States Tax Court · 1953
- Beck Chemical Equipment Corp. v. CommissionerUnited States Tax Court · 1957
- Flanagan v. HelveringCourt of Appeals for the D.C. Circuit · 1940
- Walter H. Kaltreider and Irene C. Kaltreider v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1958
21 more not listed; retrieve them via the Exa API.
3Cited by66 opinions
- Stevens Bros. Foundation, Inc. v. CommissionerUnited States Tax Court · 1962
- Lewis v. CommissionerUnited States Tax Court · 1960
- Service Bolt & Nut Co. Profit Sharing Trust v. CommissionerUnited States Tax Court · 1982
- Meyer v. CommissionerUnited States Tax Court · 1966
- Thomas Kerr and Barbara Kerr v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1964
61 more not listed; retrieve them via the Exa API.