T.C. Memo. 1996-83
UNITED STATES TAX COURT
JAMES P. WHITMER, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 1135-95. Filed February 26, 1996.
Frederick M. Cuppy, Todd A. Etzler, and Edward L. Burke,
for petitioner.
Ronald T. Jordan, for respondent.
P guaranteed the obligation of M, his wholly owned
corporation, under M’s contracts with I. Pursuant to
these contracts, I paid advance commissions to M and
its agents for insurance policies that they sold, and
M had to repay these commissions if the policies lapsed
or were canceled. After I terminated its business
relationship with P and M, I sued M for repayment of
advance commissions and loans. P was named as a
co-defendant because he guaranteed the debt. P and M
countersued for reasons that were essentially unrelated
to P’s claim. In settlement of the litigation, the
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