Sala v. Commissioner

47 B.T.A. 850, 1942 BTA LEXIS 637
CourtUnited States Board of Tax Appeals
DecidedOctober 8, 1942
DocketDocket No. 103863.
StatusPublished
Cited by1 cases

This text of 47 B.T.A. 850 (Sala v. Commissioner) is published on Counsel Stack Legal Research, covering United States Board of Tax Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Sala v. Commissioner, 47 B.T.A. 850, 1942 BTA LEXIS 637 (bta 1942).

Opinion

[853]*853OPINION.

Van Fossan:

The issue before us is whether or not the write-down of accounts receivable due from the petitioner to the corporations of which she was the sole stockholder was, in effect, a dividend to her.

There is no controversy between the petitioner and the respondent that under certain circumstances the write-down of an account receivable by a corporation from the stockholder may constitute a dividend. The question here is: Do the facts in the case at bar warrant such a conclusion ? We find that they do.

[854]*854There is one fundamental fact that stands out with startling significance, one which the petitioner relies upon to absolve her from the proposed tax liability but which has precisely the opposite effect. That fact is that she delegated to her uncle, J. S. Bache, the complete and absolute management and control of her financial affairs. She thus conclusively constituted him her agent and representative.

It is well to review the salient events that occurred in the year 1930. The petitioner’s husband, Edwin S. Bayer, had died in 1928. He left a will establishing certain legacies but not sufficient estate to pay them. The petitioner’s own personal financial situation had become very much involved. She then, in 1930, went to her uncle to seek his advice in solving her fianancial problems. He agreed to help her on the condition, in which she acquiesced, that he be given carte Manche to conduct her affairs as he saw fit, with no interference whatever from her. Thereafter he took over her stock in Broadex and Ideal, secured loans for her, and made all arrangements for the future conduct of all of her business matters.

Bache, with the petitioner’s complete compliance, delegated to Nathan, his own personal attorney and the attorney of all persons and corporations materially involved in the situation, questions of law and policy thought necessary to the successful consummation of Bache’s endeavors. All officers and directors of the corporations, other than Bache and Nathan, were mere figureheads.

During 1930 the petitioner withdrew as loans over $760,000 from both corporations. The record is silent whether she did so on the advice of Nathan, under the direction of Bache, or upon her own initiative. She received $50,000 as the president of Broadex and Ideal, although she denied all knowledge of the operation of the companies and of business affairs in general. She rendered no services whatever to the corporations. She also amassed over $116,000 in stock dividends. The total is over $926,000. She paid no income tax that year. Her return showed an item of over $119,000 as “interest paid” but no explanatory or itemized notation thereon.

The condition of the petitioner’s affairs remained practically the same until 1935, with the exception of the withdrawals which had mounted to over $2,000,000. The withdrawals were entered and carried on the books of Broadex and Ideal as accounts receivable. On January 15 and December 24-, 1935, by the authority of their boards of directors, Broadex and Ideal “wrote down” the petitioner’s accounts receivable by $500,000 and $700,000, respectively. Those amounts were deemed uncollectible. Proper entries were made on the corporate books to evidence such action and the surplus accounts were reduced correspondingly. However, during 1935 and after January 15 of that year Ideal advanced an additional sum of $7,952.40 to the petitioner.

The picture is not complete without reference to the events occur[855]*855ring in 1938. On April 26 of that year, by formal action, the directors of Broadex and Ideal wrote off the entire amounts of their claims against the petitioner “as presently uncollectible” and eliminated those items from their balance sheets. On October 13, 1938, they restored to their books and balance sheets the entire original amounts of their several accounts receivable from the petitioner* as they appeared thereon prior to January 15,1935.

The petitioner submits a many-sided defense the principal points of which are that the write-downs did not constitute a cancellation, forgiveness, or release; that there was no intent to forgive or release any part of the indebtedness; that she had no knowledge of and,expressed no acquiescence in or consent to such write-downs; that her financial condition was not improved; that she had no.control or. voice in the management of Broadex and Ideal; and that the restoration resolutions in 1938 show that the write-downs in 1935 were mere bookkeeping entries.

We are impressed with none of these arguments. They might have some bearing if a different relationship had existed between the petitioner and Bache, Nathan, Broadex, and Ideal. See Waggaman v. Helvering, 78 Fed. (2d) 721; certiorari denied, 296 U. S. 618; Jas. J. Gravley, 44 B. T. A. 722.

. The vital element in the situation here is that the petitioner voluntarily and deliberately turned over all of her affairs, including all moneys and transactions which might affect her income tax, to her uncle and Nathan, who thereupon acted in her place and stead. The petitioner now seeks to be exculpated from the normal and logical tax consequences of her act. Having established Bache and Nathan as the managers of her property and income, the responsibility of their maneuvers rests upon her and no disclaimer of hers can be effective.

To allow a taxpayer to avoid or evade the natural and inevitable results of actions taken by his representatives in his behalf, by the simple expedient of turning over his property and its management to them, would afford an invitation to collusion and fraud. We can not countenance such a scheme.

The petitioner’s attorneys argue that Bache, Nathan, Broadex, and Ideal were motivated only by their own personal interests and had no thought of the petitioner when the various resolutions were adopted and the concomitant book entries made. We can not ignore the multiple capacities in which both Bache and Nathan acted, nor can we believe that when the actions of record were taken they suddenly forgot the petitioner and proceeded solely in the interests of others. The petitioner is charged with the knowledge which her agents possessed — they were acting in matters of vital importance to her welfare and pecuniary benefit. She can not successfully plead ignorance and innocence.

[856]*856We must remember also that the petitioner was the sole owner of the stock of Broadex and Ideal. For the sake of convenient handling, the stock of these corporations had been deposited with Bache and he apparently was able to vote it whenever a vote was required. Howeyer, she still remained its owner.

We deem it unnecessary to comment at length on the recorded inconsistencies relating to the petitioner’s alleged financial difficulties in 1935 or 1988 resulting in the various book entries. We note that potential or actual tax difficulties arose. That fact is no justification for playing fast and loose with corporate books and records.

We observe that following the resolution of January 15, 1935, adopted by the Broadex directors (the majority of whom were also Ideal’s directors), Ideal advanced to the petitioner almost $8,000. However, we will take the resolutions of January 15,1935, at their face value, consider the petitioner’s accounts receivable partially uncol-lectible, and agree that Broadex and Ideal were warranted in writing the uncollectible portions thereof off their books.

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Related

Sala v. Commissioner
47 B.T.A. 850 (Board of Tax Appeals, 1942)

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Bluebook (online)
47 B.T.A. 850, 1942 BTA LEXIS 637, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sala-v-commissioner-bta-1942.