Fincher v. Commissioner
United States Tax Court
P was an officer of an S & L. The S & L was placed into conservatorship on May 12, 1987. The order establishing conservatorship stated that officers of the S & L would serve in accordance with the directions and under the authority of the conservator.
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P was an officer of an S & L. The S & L was placed into conservatorship on May 12, 1987. The order establishing conservatorship stated that officers of the S & L would serve in accordance with the directions and under the authority of the conservator. The S & L was closed for liquidation on Apr. 28, 1988. At the time the S & L was placed into conservatorship, Ps had personal and business deposits in the S & L. Independent of his position at the S & L, P personally guaranteed loans, but did not receive consideration for most of the guaranties. In order to satisfy one of the guaranties, P…
1Opinion of the Court
Parr, Judge:
Respondent determined deficiencies in and additions to petitioners’ Federal income taxes as follows:
Additions to tax
Sec. Sec. Sec Year Deficiency 6653(a)(1)(A) 6653(a)(1)(B) 6653(a)(1)
1984 $79,577
1985 26,123
1987 47,137 $2,357 1
1988 4,336 $217
All section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure, unless otherwise indicated.
This case involves the disallowance of two types of deductions: Deductions of an estimated amount of petitioners’ deposits in Rio Grande Savings &…
2Cases cited17 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Consumer Product Safety Commission v. GTE Sylvania, Inc.Supreme Court of the United States · 1980
- Neely v. CommissionerUnited States Tax Court · 1985
- Carlos and Jacqueline Marcello v. Commissioner of Internal Revenue, Joseph, Jr. And Anastasia Marcello v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1967
- United States v. GeneresSupreme Court of the United States · 1972
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