Legal Opinion

Estate of Allison v. Commissioner

United States Tax Court

Decided November 1, 1971No. Docket No. 5709-69Published

Decedent received interest-bearing notes for the major portion of substantial advances made to an electing small business corporation of which he was a shareholder. Held, even if such advances are considered contributions to capital, rather than bona fide indebtedness, such advances and notes do not constitute a second class of stock under sec. 1371(a) (4), I.R.C. 1954.

1Opinion of the Court

Estate of William M. Allison, Deceased, the First National Bank of Chicago, and Henry F. Tenney, Coexecutors, Petitioner v. Commissioner of Internal Revenue, Respondent

Estate of Allison v. Commissioner

Docket No. 5709-69

United States Tax Court

57 T.C. 174; 1971 U.S. Tax Ct. LEXIS 33;

November 1, 1971, Filed

Decision will be entered under Rule 50.

Decedent received interest-bearing notes for the major portion of substantial advances made to an electing small business corporation of which he was a shareholder. Held, even if such advances are considered contributions to capital, rather than bona fide…

2Cases cited11 opinions

  1. Commissioner of Internal Revenue v. OPP Holding Corp.Court of Appeals for the Second Circuit · 1935
  2. Raynor v. CommissionerUnited States Tax Court · 1968
  3. Jewel Tea Co. v. United StatesCourt of Appeals for the Second Circuit · 1937
  4. Gamman v. CommissionerUnited States Tax Court · 1966
  5. Stinnett v. CommissionerUnited States Tax Court · 1970

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