Supreme Court· 3/27/1972
United States v. Generes
Citations
- 405 U.S. 93
- 92 S. Ct. 827
- 31 L. Ed. 2d 62
- 1972 U.S. LEXIS 151
How courts have described this case
Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.
- holding that a taxpayer's trade or business must be the \dominant motivation\ for a loan
- stating that to qualify for the business bad debt deduction the taxpayer's trade or business must be the dominant motivation for making the guaranties
- stating that “corporation has a personality separate from its shareholders and ... its business is not necessarily their business”
- finding that the witness' testimony, standing alone, did not \bear the light of analysis\
- considering the ratio of salary to debt amount a significant factor to find business purpose for an employee loan
- discussing the consistency of the meaning of “trade or business” across sections 162, 166, and 165
Source: CourtListener parenthetical corpus (CC0).
Judges: Blackmun, Burger, Stewart, Marshall, Brennan, White, Douglas, Powell, Rehnquist
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