Taylor v. Commissioner
United States Tax Court
In 1973, petitioners guaranteed a $ 300,000 loan made to a partnership by a bank. The partnership transferred $ 140,000 of the loan proceeds to a medical clinic in which petitioner-husband practiced as a physician and held a substantial stock investment. The partnership did not engage in any trade or business. In 1973, petitioner-husband also borrowed $ 44,772 from the bank. The partnership and petitioner-husband defaulted on their respective loans.
Read the full summary
In 1973, petitioners guaranteed a $ 300,000 loan made to a partnership by a bank. The partnership transferred $ 140,000 of the loan proceeds to a medical clinic in which petitioner-husband practiced as a physician and held a substantial stock investment. The partnership did not engage in any trade or business. In 1973, petitioner-husband also borrowed $ 44,772 from the bank. The partnership and petitioner-husband defaulted on their respective loans. In settlement of their obligations on the personal loan and the guaranty, petitioners executed a $ 37,500 promissory note to the bank which had…
1Opinion of the Court
WILLIS D. TAYLOR AND SANDRA B. TAYLOR, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Taylor v. Commissioner
Docket No. 35152-83
United States Tax Court
T.C. Memo 1989-331; 1989 Tax Ct. Memo LEXIS 327; 57 T.C.M. (CCH) 895; T.C.M. (RIA) 89331;
July 11, 1989
In 1973, petitioners guaranteed a $ 300,000 loan made to a partnership by a bank. The partnership transferred $ 140,000 of the loan proceeds to a medical clinic in which petitioner-husband practiced as a physician and held a substantial stock investment. The partnership did not engage in any trade or business. In 1973,…
2Cases cited19 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Commissioner v. GroetzingerSupreme Court of the United States · 1987
- Whipple v. CommissionerSupreme Court of the United States · 1963
- Putnam v. CommissionerSupreme Court of the United States · 1956
- United States v. GeneresSupreme Court of the United States · 1972
14 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Bernstein v. CommissionerUnited States Tax Court · 1989