Legal Opinion

Sika Chemical Corp. v. Commissioner

United States Tax Court

Decided August 7, 1975No. Docket No. 6727-73PublishedCited by 12 opinions

Petitioner, relying solely on balance sheet book value figures and consistent yearly losses, but without considering "going concern" values, charged off a portion of its subsidiary's debt as partially worthless under sec. 166(a)(2), I.R.C. 1954. Held, respondent's disallowance not shown to be arbitrary or unreasonable especially in view of fact that liquidation of the subsidary was not shown to have been contemplated nor to have occurred.

1Opinion of the Court

Forrester, Judge:

Respondent has determined the following deficiencies in petitioner’s Federal income taxes:

TYE Dee. 31— Deficiency

1964_ $11,378.01

1965_ 8,986.46

1966_ 60,504.08

1967_ 37,201.28

Because of a concession by petitioner, the only issue remaining for our decision is whether petitioner was entitled to bad debt loss treatment in 1967 for a part of certain advances made to its wholly owned Canadian subsidiary.

FINDINGS OF FACT

All of the facts have been stipulated and are so found.

Sika Chemical Corp. (petitioner), which was incorporated under the laws of the State of New Jersey, had its…

2Cases cited18 opinions

  1. Herbert W. Dustin and Kathleen C. Dustin v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1972
  2. Dustin v. CommissionerUnited States Tax Court · 1969
  3. Riss v. CommissionerUnited States Tax Court · 1971
  4. Morton v. CommissionerUnited States Board of Tax Appeals · 1938
  5. Morton v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1940

13 more not listed; retrieve them via the Exa API.

3Cited by12 opinions

  1. Austin Co. v. CommissionerUnited States Tax Court · 1979
  2. Arkansas Best Corp. v. CommissionerUnited States Tax Court · 1984
  3. Record Wide Distributors, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1982
  4. HAWKINS v. COMMISSIONERUnited States Tax Court · 1987
  5. IDI Management, Inc. v. CommissionerUnited States Tax Court · 1977

7 more not listed; retrieve them via the Exa API.

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