Legal Opinion

Charles H. Davison and Leslie B. Davison v. Commissioner

United States Tax Court

Decided August 26, 1996No. 15887-94Unknown

1Opinion of the Court

107 T.C. No. 4

UNITED STATES TAX COURT CHARLES H. DAVISON AND LESSIE B. DAVISON, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 15887-94. Filed August 26, 1996. W, a cash basis partnership, entered into an agreement in 1980 to borrow up to $29 million from J. J made an initial disbursement of $19,645,000. Pursuant to the loan agreement, J applied $227,647.22 of the initial disbursement as a credit for interest W owed to J on a previous loan. Pursuant to a subsequent modification of the 1980 loan agreement, J agreed to advance $1,587,310.46 to W to enable W to satisfy…

2Cases cited20 opinions

  1. Minnesota Tea Co. v. HelveringSupreme Court of the United States · 1938
  2. Eckert v. BurnetSupreme Court of the United States · 1931
  3. Eli D. Goodstein v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. Eli D. GoodsteinCourt of Appeals for the First Circuit · 1959
  4. Don E. Williams Co. v. CommissionerSupreme Court of the United States · 1977
  5. Nat Harrison Assoc., Inc. v. CommissionerUnited States Tax Court · 1964

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