Legal Opinion
Royalty Service Corporation v. United States
District Court, D. Montana
Decided November 12, 1959No. Civ. 1994-1998PublishedCited by 6 opinions
1Opinion of the Court
JAMESON, District Judge.
In five actions, consolidated for trial, the taxpayer, Royalty Service Corporation, seeks a refund of corporate income taxes for the years 1949, 1950, 1951, 1952 and 1953. The cases were submitted upon an agreed statement of facts, supplemented by testimony of the president, secretary-treasurer, and accountant of the plaintiff taxpayer.
The primary question is whether payment by the taxpayer on promissory notes held by two stockholders constituted interest within the meaning of Section 23(b) or distribution of profits within the meaning of Section 115(a) of the Internal…
2Cases cited14 opinions
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- John Kelley Co. v. CommissionerSupreme Court of the United States · 1946
- Benjamin D. And Madeline Prentice Gilbert v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1957
- Dobkin v. CommissionerUnited States Tax Court · 1950
- John v. Rowan v. United StatesCourt of Appeals for the Fifth Circuit · 1955
9 more not listed; retrieve them via the Exa API.
3Cited by6 opinions
- Jack Daniel Distillery, Lem Motlow, Prop., Inc. v. The United StatesUnited States Court of Claims · 1967
- Santa Anita Consol., Inc. v. CommissionerUnited States Tax Court · 1968
- Bordo Products Co. v. United StatesUnited States Court of Claims · 1973
- Castle Heights, Inc. v. United StatesDistrict Court, E.D. Tennessee · 1965
- Hirs v. United StatesDistrict Court, S.D. Alabama · 1965
1 more not listed; retrieve them via the Exa API.