Sekulow v. Commissioner

1980 T.C. Memo. 564, 41 T.C.M. 582, 1980 Tax Ct. Memo LEXIS 25
CourtUnited States Tax Court
DecidedDecember 17, 1980
DocketDocket No. 7836-78
StatusUnpublished

This text of 1980 T.C. Memo. 564 (Sekulow 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
Sekulow v. Commissioner, 1980 T.C. Memo. 564, 41 T.C.M. 582, 1980 Tax Ct. Memo LEXIS 25 (tax 1980).

Opinion

ABRAHAM SEKULOW AND FLORENCE SEKULOW, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Sekulow v. Commissioner
Docket No. 7836-78
United States Tax Court
T.C. Memo 1980-564; 1980 Tax Ct. Memo LEXIS 25; 41 T.C.M. (CCH) 582; T.C.M. (RIA) 80564;
December 17, 1980
David R. Cohan, for the petitioners.
John F. Dean, for the respondent.

WILBUR

MEMORANDUM FINDINGS OF FACT AND OPINION

WILBUR, Judge: Respondent determined a deficiency in the amount of $ 5,008 in petitioners' Federal income taxes for 1974. The issues for decision are: (1) whether petitioners advanced sums to a corporation; (2) whether such sums represented bona fide loans or contributions to the corporation's capital; (3) to the extent the funds advanced to the corporation are considered loans, did they constitute business bad debts under section 166; 1 and (4) if they are bad debts under section 166, were they partially worthless in 1974.

FINDINGS*26 OF FACT

Some of the facts have been stipulated and are found accordingly.

Petitioners 2 resided in Baltimore, Maryland at the time the petition in this case was filed. They filed their joint Federal income tax return for the year 1974 with the District Director at Philadelphia, Pennsylvania.

Petitioner and his brother founded Sekulow Brothers over 50 years ago, and incorporated the business in 1940. Sekulow Brothers, Inc. is in the ladies' millinery business. The corporation was petitioner's sole source of income. In 1972, after buying up his brother's shares, petitioner became president and majority stockholder. Petitioner, his wife, and son then owned all the shares of the corporation.

Starting around 1971, the corporation sustained operating losses which became progressively larger as the years went by. In 1973, the situation deteriorated and the corporation did not have the funds necessary to meet its payroll. In order to raise funds to continue operations, the corporation made substantial efforts to obtain*27 loans from banks and other financial institutions, but was turned down whenever a loan was requested. Efforts were made to obtain inventory financing through sources other than banks, including personal and business acquaintances, but all efforts to obtain money from outside sources also were unsuccessful. To meet the payroll expenses, two withdrawals totalling $ 29,000 were made from the Sekulow Brothers, Inc. pension trust in 1973 and put into the ailing business. The pension trust account had been set up as a spendthrift trust in 1966 to provide retirement benefits to employees. Petitioner was a trustee. The trust entered the transaction on its books as a receivable from Sekulow Brothers, Inc. No notes or other evidence of indebtedness were created. In November 1973, $ 5,000 was paid back to the trust by the corporation.

The business continued to lose money. By the end of the fiscal year ending August 31, 1973 operating losses totalled over $ 100,000 and by the end of the 1974 fiscal year, the losses had reached almost $ 300,000. Sekulow Brothers filed for a Chapter XI reorganization in 1974, and the plan was approved in January of 1976. The plan provided that creditors*28 would get 20 cents on the dollar over the next five years, paid out 2-1/2 cents a year for the first two years, then 5 cents a year for the next 3 years. The trust was not listed among the outstanding creditors and petitioner did not file a creditor's claim for any amount. Petitioner, upon the advice of his attorney, was of the opinion that the outside creditors would not approve a plan, or at a minimum its chances for success would be severely jeopardized, were he to post a claim against the corporation's assets when the other creditors stood to lose 80 percent of their investment if he did not file a claim--and even more if he did submit one. No record of loans from stockholders appears until the fiscal year ending August 31, 1975, at which time loans of $ 38,500 were listed on the corporation's tax return.

The trust was later terminated, and the proceeds went to pay benefits to all the employees save Mr. Sekulow. He alone suffered the loss of the sums advanced to the corporation. In March, 1979 the corporation went bankrupt.

In 1974, petitioner deducted $ 15,200 from his income tax return as a partially worthless bad debt. He contends that the $ 38,500 ($ 29,000 from*29 the trust and $ 9,500 from other unspecified sources) represented his own funds and his pension money, and that he loaned this sum to the corporation as a short-term loan, hopefully to have been paid back after the big hat season around Easter and Mother's Day. The money was not paid back, save for the $ 5,000 put back into the trust. Petitioner argues that the loan became at least 40 percent worthless in 1974. This 40 percent figure was arrived at after talking with his auditor. The respondent denied the deduction in full, arguing that (1) the advances did not come from Mr. Sekulow, but from the trust; (2) even if Mr. Sekulow was the source, the sums advanced represented contributions to capital and not loans; (3) if they were loans, they were nonbusiness loans; (4) even if they were bad debts under section 166, they were not partially worthless in 1974.

OPINION

Petitioner and his brother had been in the millinery business for over 50 years. Since 1940, they have been incorporated under the name Sekulow Brothers, Inc. In 1972, petitioner bought up his brother's shares.

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1980 T.C. Memo. 564, 41 T.C.M. 582, 1980 Tax Ct. Memo LEXIS 25, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sekulow-v-commissioner-tax-1980.