Legal Opinion

Dunn v. Commissioner

United States Tax Court

Decided November 1, 1963No. Docket No. 92129Unpublished

1. Petitioners' advances to two corporations in which they were the only stockholders held to be nonbusiness bad debts or additional investments in the corporations, the losses on which were deductible as a capital loss. 2. Petitioners are liable for additions to tax for failure to file a declaration of estimated tax for 1954 and for late filing of their income tax returns for 1957 and 1958.

1Opinion of the Court

William E. Dunn and Beatrice E. Dunn v. Commissioner.

Dunn v. Commissioner

Docket No. 92129.

United States Tax Court

T.C. Memo 1963-301; 1963 Tax Ct. Memo LEXIS 45; 22 T.C.M. (CCH) 1583; T.C.M. (RIA) 63301;

November 1, 1963

1. Petitioners' advances to two corporations in which they were the only stockholders held to be nonbusiness bad debts or additional investments in the corporations, the losses on which were deductible as a capital loss.

2. Petitioners are liable for additions to tax for failure to file a declaration of estimated tax for 1954 and for late filing of their income tax returns for…

2Cases cited18 opinions

  1. Gregory v. HelveringSupreme Court of the United States · 1935
  2. Whipple v. CommissionerSupreme Court of the United States · 1963
  3. Putnam v. CommissionerSupreme Court of the United States · 1956
  4. Burnet v. ClarkSupreme Court of the United States · 1932
  5. John M. Trent and Lisa M. Trent v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1961

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