Legal Opinion

Vincent C. Giblin v. Commissioner of Internal Revenue

Court of Appeals for the Fifth Circuit

Decided November 23, 1955No. 15587PublishedCited by 67 opinions

1Opinion of the Court

TUTTLE, Circuit Judge.

This is a petition for review of a decision of the Tax Court involving income taxes for 1945. The questions presented for our consideration are .two. First, whether loans made by taxpayer to a corporation, of which he was an officer, director, large stockholder and principal actor, are deductible in full as a business bad debt under Section 23 (k) (1) of the Internal Revenue Code of 1939, 26 U.S. C.A., or whether these loans are deductible only under Section 23 (k) (4) as a non-business bad debt not incurred m taxpayer’s trade or business, and are thus to be taken into…

2Cases cited16 opinions

  1. Higgins v. CommissionerSupreme Court of the United States · 1941
  2. John v. Rowan v. United StatesCourt of Appeals for the Fifth Circuit · 1955
  3. Campbell v. CommissionerUnited States Tax Court · 1948
  4. Maloney v. SpencerCourt of Appeals for the Ninth Circuit · 1949
  5. Foss v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1935

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

3Cited by67 opinions

  1. Whipple v. CommissionerSupreme Court of the United States · 1963
  2. Clement L. Hirsch v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1963
  3. Millsap v. CommissionerUnited States Tax Court · 1966
  4. John M. Trent and Lisa M. Trent v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1961
  5. H. Beale Rollins and Mary E. Rollins v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1960

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

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