Legal Opinion
Matthiessen v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided February 15, 1952No. 22142_1PublishedCited by 67 opinions
1Opinion of the Court
BRENNAN, District Judge.
This appeal challenges a decision of the Tax Court, 16 T.C. 781, which upheld the Commissioner’s determination of a deficiency of about $34,000 in the petitioners’ income tax liability. The litigation arises by reason of the re-audit of petitioners’ joint tax return for the year 1941. It was held that corporate obligations represented by promissory notes payable to the petitioners, who were husband and wife and the sole stockholders of the corporation, represented contributions to capital rather than loans and, therefore, not deductible as bad debts in the petitioners’…
2Cases cited7 opinions
- Helvering v. National Grocery Co.Supreme Court of the United States · 1938
- White v. United StatesSupreme Court of the United States · 1938
- Schnitzer v. CommissionerUnited States Tax Court · 1949
- Dobkin v. CommissionerUnited States Tax Court · 1950
- Janeway v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1945
2 more not listed; retrieve them via the Exa API.
3Cited by67 opinions
- John v. Rowan v. United StatesCourt of Appeals for the Fifth Circuit · 1955
- Benjamin D. And Madeline Prentice Gilbert, on Review v. Commissioner of Internal Revenue, on ReviewCourt of Appeals for the Second Circuit · 1959
- Jack Daniel Distillery, Lem Motlow, Prop., Inc. v. The United StatesUnited States Court of Claims · 1967
- Gooding Amusement Co. v. CommissionerCourt of Appeals for the Sixth Circuit · 1956
- C. M. Gooch Lumber Sales Co. v. CommissionerUnited States Tax Court · 1968
62 more not listed; retrieve them via the Exa API.