Legal Opinion

Hitchins v. Commissioner

United States Tax Court

Decided December 22, 1994No. Docket No. 23063-92Published

P-husband loaned money to CCC, a subchapter C corporation, and received a note of CCC evidencing the loan. It was anticipated that CCC would develop a chemical database for a corporation subsequently to be formed. CMB was later formed with P-husband as a shareholder. CMB gave a note to CCC for the amount the latter had expended in developing the database. Subsequently, CMB paid that note by way of cash and assuming CCC's indebtedness to P-husband.

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P-husband loaned money to CCC, a subchapter C corporation, and received a note of CCC evidencing the loan. It was anticipated that CCC would develop a chemical database for a corporation subsequently to be formed. CMB was later formed with P-husband as a shareholder. CMB gave a note to CCC for the amount the latter had expended in developing the database. Subsequently, CMB paid that note by way of cash and assuming CCC's indebtedness to P-husband. CCC's note was not canceled, nor did CMB give its note to P-husband. CMB elected subchapter S status. Held, the amount loaned by P-husband to CCC…

1Opinion of the Court

F. Howard Hitchins and Esther E. Hitchins, Petitioners v. Commissioner of Internal Revenue, Respondent

Hitchins v. Commissioner

Docket No. 23063-92

United States Tax Court

103 T.C. 711; 1994 U.S. Tax Ct. LEXIS 84; 103 T.C. No. 40;

December 22, 1994, Filed

Decision will be entered under Rule 155.

P-husband loaned money to CCC, a subchapter C corporation, and received a note of CCC evidencing the loan. It was anticipated that CCC would develop a chemical database for a corporation subsequently to be formed. CMB was later formed with P-husband as a shareholder. CMB gave a note to CCC for the amount the…

2Cases cited23 opinions

  1. Neely v. CommissionerUnited States Tax Court · 1985
  2. Bixby v. CommissionerUnited States Tax Court · 1972
  3. Commissioner v. National Alfalfa Dehydrating & Milling Co.Supreme Court of the United States · 1974
  4. Antonides v. CommissionerUnited States Tax Court · 1988
  5. Don E. Williams Co. v. CommissionerSupreme Court of the United States · 1977

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