Continental Illinois Nat'l Bank & Trust Co. v. Commissioner
United States Tax Court
In 1963 petitioner purchased an interest in conditional sales contracts and chattel mortgages guaranteed by corporations A, B, and C. During 1963, A, B, and C all filed petitions in bankruptcy under ch. XI, and petitioner filed claims therein with respect to the guarantees.
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In 1963 petitioner purchased an interest in conditional sales contracts and chattel mortgages guaranteed by corporations A, B, and C. During 1963, A, B, and C all filed petitions in bankruptcy under ch. XI, and petitioner filed claims therein with respect to the guarantees. Pursuant to the plan of arrangement, as confirmed, petitioner received in complete satisfaction of the contingent liability of A, B, and C, inter alia, two 10-year subordinated debentures of A and common stock of A. Petitioner nominally valued these assets at $ 1 each, writing off (after accounting for recoveries on the…
1Opinion of the Court
Wilbur, Judge:
Respondent determined a deficiency in petitioner’s Federal income tax for the taxable year 1968 in the amount of $376,950.59.1
Certain issues having been settled by the parties, the following issues remain for our decision:(1) Whether the donation of appreciated Tastee Freez common stock to a charitable foundation resulted in the recovery of a previously deducted item which must be returned to income under the tax benefit rule; and(2) Whether in the light of the Corn Products doctrine, the gain realized by petitioner on the sale of its stock in the Credit Bureau of Cook County,…
2Cases cited37 opinions
- Burnet v. HarmelSupreme Court of the United States · 1932
- Dobson v. CommissionerSupreme Court of the United States · 1944
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- Burnet v. Sanford & Brooks Co.Supreme Court of the United States · 1931
- Arrowsmith v. CommissionerSupreme Court of the United States · 1952
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3Cited by12 opinions
- Miller v. CommissionerUnited States Tax Court · 1978
- Anderson v. United StatesDistrict Court, D. Minnesota · 1979
- In Re ButcherUnited States Bankruptcy Court, E.D. Tennessee · 1989
- American Financial Corp. v. CommissionerUnited States Tax Court · 1979
- Rosen v. CommissionerUnited States Tax Court · 1978
7 more not listed; retrieve them via the Exa API.