Hudson v. Commissioner
United States Tax Court
Held, for Federal income tax purposes, purported promissory notes associated with petitioner's investment in educational master audio tapes do not constitute genuine indebtedness.
1Opinion of the Court
Swift, Judge:
Respondent determined deficiencies in and additions to petitioner’s individual Federal income tax as follows:
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Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.
The issues remaining for decision are: (1) Whether purported promissory notes associated with an investment in educational master audio tapes had economic substance and constituted genuine indebtedness that is to be recognized for Federal income tax purposes; (2) the…
2Cases cited36 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- Crane v. CommissionerSupreme Court of the United States · 1947
- United States v. Kirby Lumber CoSupreme Court of the United States · 1931
31 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
- Connecticut Yankee Atomic Power Co. v. United StatesUnited States Court of Federal Claims · 1997
- Hudson v. CommissionerUnited States Tax Court · 1994
- Richie v. CommissionerUnited States Tax Court · 1995