Roesel v. Commissioner
United States Tax Court
On Feb. 28, 1963, and Feb. 29, 1964, a qualifying subchapter S corporation issued checks to its shareholders, including the petitioners, in the amounts of $ 345,000 and $ 165,745, respectively. On or about Mar. 1, 1963, and Mar. 1, 1964, the shareholders issued their checks to the corporation in the amounts of $ 117,500 and $ 69,505, respectively, and received debentures and short-term notes of the corporation in such amounts.
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On Feb. 28, 1963, and Feb. 29, 1964, a qualifying subchapter S corporation issued checks to its shareholders, including the petitioners, in the amounts of $ 345,000 and $ 165,745, respectively. On or about Mar. 1, 1963, and Mar. 1, 1964, the shareholders issued their checks to the corporation in the amounts of $ 117,500 and $ 69,505, respectively, and received debentures and short-term notes of the corporation in such amounts. Held, that in substance the issuance by the corporation of the above checks did not constitute distributions of money in the full amounts thereof, but rather the…
1Opinion of the Court
George A. Roesel and Patricia M. Roesel, Petitioner v. Commissioner of Internal Revenue, Respondent; Dorothy H. Marbut, Petitioner v. Commissioner of Internal Revenue, Respondent
Roesel v. Commissioner
Docket Nos. 374-68, 375-68
United States Tax Court
56 T.C. 14; 1971 U.S. Tax Ct. LEXIS 156;
April 7, 1971, Filed
Decisions will be entered under Rule 50.
On Feb. 28, 1963, and Feb. 29, 1964, a qualifying subchapter S corporation issued checks to its shareholders, including the petitioners, in the amounts of $ 345,000 and $ 165,745, respectively. On or about Mar. 1, 1963, and Mar. 1, 1964, the…
2Cases cited3 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Roesel v. CommissionerUnited States Tax Court · 1971
- DeTreville v. United StatesDistrict Court, D. South Carolina · 1969