Levine v. Commissioner
United States Tax Court
Petitioner's loans to corporation, and unrecouped guaranty payment, later transferred for nominal amount, being wholly uncollectible and proximately related to petitioner's individual business, held, to constitute business bad debts deductible as such rather than merely as capital losses.
1Opinion of the Court
Mac Levine and Anne E. Levine, Petitioners, v. Commissioner of Internal Revenue, Respondent
Levine v. Commissioner
Docket No. 57760
United States Tax Court
31 T.C. 1121; 1959 U.S. Tax Ct. LEXIS 230;
February 27, 1959, Filed
Decision will be entered under Rule 50.
Petitioner's loans to corporation, and unrecouped guaranty payment, later transferred for nominal amount, being wholly uncollectible and proximately related to petitioner's individual business, held, to constitute business bad debts deductible as such rather than merely as capital losses.
George B. Lourie, Esq., and Arnold R. Cutler, Esq.,…
2Cases cited16 opinions
- Burnet v. ClarkSupreme Court of the United States · 1932
- De Loss v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1928
- Berwind v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1954
- Blum v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1950
- Williams v. CommissionerUnited States Tax Court · 1957
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