Dial v. Commissioner
United States Tax Court
1. Petitioners Robert J. Dial and Dwight S. Spreng were members and trustees of an incorporated nonprofit medical clinic and drew salaries for their professional services to it. From 1936 to 1945, because of the Clinic's financial difficulties, it was unable to pay the full amount of the salaries credited to their accounts.
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1. Petitioners Robert J. Dial and Dwight S. Spreng were members and trustees of an incorporated nonprofit medical clinic and drew salaries for their professional services to it. From 1936 to 1945, because of the Clinic's financial difficulties, it was unable to pay the full amount of the salaries credited to their accounts. During that time, they also advanced money to or made payments on behalf of the Clinic, for which they were not reimbursed, but which were credited to their accounts. In 1945 their undrawn accounts totaled $ 120,000. In that year, they, together with Dwight's wife,…
1Opinion of the Court
Rice, Judge:
These consolidated proceedings involve the following contested deficiencies in income tax determined by the respondent:
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The main issue raised by the pleadings is whether mortgage notes or bonds issued to petitioners Robert J. Dial and Dwight S. Spreng in 1945 by the Lorain Avenue Clinic were in payment of past salary and other indebtedness owed by it to petitioners, and, if so, to what extent such notes or bonds constituted income to them for that year. If the answer to the first issue is “no,” two alternative issues arise as to whether petitioner Dwight S. Spreng…
2Cases cited8 opinions
- Segrist v. CrabtreeSupreme Court of the United States · 1889
- Hyland v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1949
- Scales v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1954
- Schlemmer v. United StatesCourt of Appeals for the Second Circuit · 1938
- Cooney v. CommissionerUnited States Tax Court · 1952
3 more not listed; retrieve them via the Exa API.
3Cited by42 opinions
- Humacid Co. v. CommissionerUnited States Tax Court · 1964
- Borg v. CommissionerUnited States Tax Court · 1968
- Williams v. CommissionerUnited States Tax Court · 1957
- Burr Oaks Corp. v. CommissionerUnited States Tax Court · 1965
- Basila v. CommissionerUnited States Tax Court · 1961
37 more not listed; retrieve them via the Exa API.