Humacid Co. v. Commissioner
United States Tax Court
1. Petitioner Fritz Huntsinger and several of his business associates incorporated the Humacid Co. in 1951 to exploit an idea Huntsinger had concerning a lining for oil drill-holes. Huntsinger had a 25-percent equity interest in Humacid and was its principal creditor. The idea proved unfeasible and Humacid incurred substantial losses.
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1. Petitioner Fritz Huntsinger and several of his business associates incorporated the Humacid Co. in 1951 to exploit an idea Huntsinger had concerning a lining for oil drill-holes. Huntsinger had a 25-percent equity interest in Humacid and was its principal creditor. The idea proved unfeasible and Humacid incurred substantial losses. Huntsinger in 1953 and 1954 acquired complete control of Humacid and caused a partnership controlled by him to transfer to Humacid the operating assets of a business which the partnership or its predecessor had successfully conducted for a number of years prior…
1Opinion of the Court
Fat, Judge:
The respondent, pursuant to a statutory notice dated September 18, 1961, determined deficiencies in the income tax of petitioner, the Humacid Co., for its taxable years ended December 31, 1957, 1958, and 1959, in the respective amounts of $23,975.71, $10,192.46, and $728. Pursuant to a statutory notice also dated September 18, 1961, respondent determined deficiencies in the income tax of petitioner Fritz Huntsinger and his wife Mathilde for their taxable years ended January 31, 1959 and 1960, in the respective amounts of $31,388.43 and $1,804.69. In addition to the foregoing…
2Cases cited35 opinions
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- Helvering v. Alabama Asphaltic Limestone Co.Supreme Court of the United States · 1942
- Libson Shops, Inc., v. Koehler, District Director of Internal RevenueSupreme Court of the United States · 1957
- SoRelle v. CommissionerUnited States Tax Court · 1954
- Mill Ridge Coal Company v. George D. Patterson, District Director of Internal RevenueCourt of Appeals for the Fifth Circuit · 1959
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3Cited by43 opinions
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