Breckenridge v. Commissioner
United States Tax Court
Held: (1) Funds obtained by the fraudulent assignment of nonexistent collateral is income to P; (2) farming activity not engaged in for profit; (3) sec. 6653(a) addition imposed.
1Opinion of the Court
DON BRECKENRIDGE AND ESTATE OF MARYE M. BRECKENRIDGE, DECEASED, JAN FRENCH, INDEPENDENT PERSONAL REPRESENTATIVE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Breckenridge v. Commissioner
Docket No. 8485-79.
United States Tax Court
T.C. Memo 1983-66; 1983 Tax Ct. Memo LEXIS 715; 45 T.C.M. (CCH) 650; T.C.M. (RIA) 83066;
February 2, 1983.
Held: (1) Funds obtained by the fraudulent assignment of nonexistent collateral is income to P; (2) farming activity not engaged in for profit; (3) sec. 6653(a) addition imposed.
Edward B. Goodrich, for the petitioners.
Clyde W. Mauldin, for the…
2Cases cited15 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- James v. United StatesSupreme Court of the United States · 1961
- Dreicer v. CommissionerUnited States Tax Court · 1982
- Golanty v. CommissionerUnited States Tax Court · 1979
- Enoch v. CommissionerUnited States Tax Court · 1972
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