James P. Whitmer - Page 1

                                 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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