Brutsche v. Commissioner

65 T.C. 1034, 1976 U.S. Tax Ct. LEXIS 151
CourtUnited States Tax Court
DecidedMarch 2, 1976
DocketDocket Nos. 6818-73, 6819-73
StatusPublished
Cited by20 cases

This text of 65 T.C. 1034 (Brutsche v. Commissioner) is published on Counsel Stack Legal Research, covering United States Tax Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Brutsche v. Commissioner, 65 T.C. 1034, 1976 U.S. Tax Ct. LEXIS 151 (tax 1976).

Opinion

OPINION

Petitioners’ primary position is that Thunder Mountain was not an electing small business corporation and consequently any increase in its undistributed income for its fiscal year 1969 is not taxable to them for the calendar year 1969 but to the corporation. Petitioners stated the following bases for this position:

(1) Thunder Mountain had more than one class of stock since the loans to the corporation by Ralph were equity investments, and consequently it was ineligible to elect under section 1371(a) to be taxed as a small business corporation;

(2) Even if Thunder Mountain were eligible to elect to be taxed as a small business corporation, its election was not filed within a month of May 26, 1961, the beginning of its taxable year and therefore was ineffective; and

(3) The election was ineffective since the statement of shareholders’ consent filed with it omitted the number of shares of stock of Thunder Mountain issued to each shareholder and the dates on which such shares were acquired.

Petitioners argue that they are not estopped from asserting the invalidity of the corporation’s election as respondent did not rely on any representation made by the corporation to his detriment since at the time of the trial of this case all facts were disclosed and respondent could at that time have issued a notice of deficiency to the corporation for its fiscal year 1969, the only year for which any tax would be due from the corporation.

Petitioners contend that, if Thunder Mountain qualifies as an electing small business corporation, it did not receive any taxable income in its fiscal year 1969 from settlement of litigation with the bank and forgiveness of its indebtedness by the bank and other creditors. Petitioners argue that the corporation properly accrued claims aggregating $231,720 against the bank during its fiscal years 1965, 1966, 1967, and 1968 for losses it incurred during those years by virtue of the bank’s discontinuing the extension of credit to the corporation during early 1965 and consequently did not receive any taxable income during its fiscal year 1969 when it received the cash proceeds in the amount of $162,500 pursuant to a settlement of its pending law suit against the bank. In the alternative, petitioners argue that the net operating losses were not deductible in the fiscal years during which they arose since there was a reasonable prospect for their recovery from the bank, relying on Louis Gale, 41 T.C. 269 (1963). Petitioners argue that the recovery of the losses in its fiscal year 1969 did not result in income to the corporation since the recovery was offset by the expenses paid out of the settlement. Petitioners also contend that the corporation did not receive any taxable income from the forgiveness of its indebtedness by the bank in the amount of $161,189.77 and by its other creditors in the amount of $40,204.83 as its liabilities exceeded its assets (excluding the claim receivable of $231,730.22) before the discharge of its indebtedness to the bank and to its other creditors, and by $21,335.62 after the discharge of such indebtedness.

Petitioners contend that if the corporation received income for its fiscal year 1969 from the receipt of the cash of $162,500 in exchange for damages it incurred, its transfer of houses with a book value of $52,613.75 should be offset against the receipt and the remaining $109,886 should be excluded from the corporation’s income for its fiscal year 1969 under the tax benefit rule since its net operating losses which were deducted for its prior years did not result in any tax benefit to the corporation or its shareholders.

Respondent contends that Thunder Mountain was an electing small business corporation and that it had undistributed income in the amount of $231,730.22 for its fiscal year 1969 from the settlement of litigation and cancellation of indebtedness by the bank and other creditors. In the alternative respondent contends that, if the book value of the corporation’s assets is an accurate reflection of their fair market value, the corporation had undistributed income in the amount of $171,500 for its fiscal year 1969, having received gross income in the amount of $251,058.75 during such fiscal year consisting of the following:

Cash proceeds of settlement of litigation_ $162,500.00

Insurance refund_ 8.12

Debt forgiveness by the bank_$161,189.77

Debt forgiveness by creditors_ 40,204.83

Less: houses transferred- (52,613.75)

Net debt forgiven- $148,780.85

Net book worth 6/30/68 _(222,730.22)

Cash settlement 8/68-162,500,00

Net book worth before forgiveness-(60,230,22)

Amount realized (net book worth) after

forgiveness of debt-88,550,63

251,058.75 Total gross income.

Respondent takes the position that Ralph and Phillip as shareholders of an electing small business corporation received additional taxable income during the calendar year 1969 in the amount of their proportionate share of the corporation’s undistributed income for its fiscal year 1969, and that one-half of Phillip’s proportionate share was taxable to Ruth by virtue of the community property laws of New Mexico. Respondent also contends that Ruth received taxable income for the calendar years 1968 and 1969 to the extent of her community property one-half interest in dividend distributions in the amounts of $11,000 and $1,186.91 that Thunder Mountain made to Phillip in these years. Respondent argues that under section 446(c) the corporation cannot properly accrue in its fiscal years 1965 through 1968 amounts equal to its net operating losses for such years as a claim receivable from the bank. Further, he contends that petitioners are estopped from asserting the invalidity of the corporation’s election based on their own or the corporation’s misrepresentation in the Form 2553 filed by the corporation and in the statement of the shareholders’ consent filed by the corporation’s shareholders. In any event respondent contends the corporation’s election for its fiscal year beginning July 1, 1961, was valid since it was timely and properly made on June 26, 1961, since the corporation did not have shareholders, had not acquired assets, and had not begun doing business before May 26, 1961.

Section 1372(a)4 provides that any small business corporation with an exception not relevant under the facts of this case may elect not to be subject to income tax. Under section 1371(a)5 a small business corporation is defined in part as a corporation which does not have more than one class of stock. Petitioners contend that Thunder Mountain’s purported election under section 1372(a) was not effective as the corporation had two classes of stock and therefore was ineligible under section 1371. Petitioners argue that Ralph had greater rights in the profits and assets of the corporation by his having loaned more capital to the corporation in proportion to his ownership interest than Phillip.6 Respondent contends that Ralph’s loans did not in fact constitute equity and, if they did, that these loans were not a second class of stock under section 1371. We agree with respondent.

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Cite This Page — Counsel Stack

Bluebook (online)
65 T.C. 1034, 1976 U.S. Tax Ct. LEXIS 151, Counsel Stack Legal Research, https://law.counselstack.com/opinion/brutsche-v-commissioner-tax-1976.