Legal Opinion

Giepen v. Commissioner

United States Tax Court

Decided January 15, 1957No. Docket Nos. 51268, 51269Unpublished

Issue 1. Upon the facts, held that: (1) Loans were made by a partnership, in which petitioners were equal partners, to a corporation in the total amount claimed. (2) The total debt due the partnership as a result of the loans was secured to the extent of the face amount of a mortgage, so that only part of the entire debt was unsecured. (3) The debt became partially worthless in the partnership's fiscal year, involved here, to the extent that the loans were unsecured.

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Issue 1. Upon the facts, held that: (1) Loans were made by a partnership, in which petitioners were equal partners, to a corporation in the total amount claimed. (2) The total debt due the partnership as a result of the loans was secured to the extent of the face amount of a mortgage, so that only part of the entire debt was unsecured. (3) The debt became partially worthless in the partnership's fiscal year, involved here, to the extent that the loans were unsecured. (4) The loans did not give rise to a business bad debt within section 23(k)(1), 1939 Code, and deduction of any amount is…

1Opinion of the Court

Erica Giepen and Henry J. Roger v. Commissioner.

Giepen v. Commissioner

Docket Nos. 51268, 51269.

United States Tax Court

T.C. Memo 1957-6; 1957 Tax Ct. Memo LEXIS 246; 16 T.C.M. (CCH) 20; T.C.M. (RIA) 57006;

January 15, 1957

Issue 1. Upon the facts, held that: (1) Loans were made by a partnership, in which petitioners were equal partners, to a corporation in the total amount claimed. (2) The total debt due the partnership as a result of the loans was secured to the extent of the face amount of a mortgage, so that only part of the entire debt was unsecured. (3) The debt became partially worthless…

2Cases cited22 opinions

  1. North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
  2. Spring City Foundry Co. v. CommissionerSupreme Court of the United States · 1934
  3. Brown v. HelveringSupreme Court of the United States · 1934
  4. Burnet v. ClarkSupreme Court of the United States · 1932
  5. Dalton v. BowersSupreme Court of the United States · 1932

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