Bunker Hill & Sullivan Mining & Concentrating Co. v. Commissioner
United States Tax Court
Petitioner, owner of a 50 percent stock interest, and others, stockholders and nonstockholders, made advances from time to time to a corporation engaged in acquiring, prospecting, developing, and operating various mining properties.
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Petitioner, owner of a 50 percent stock interest, and others, stockholders and nonstockholders, made advances from time to time to a corporation engaged in acquiring, prospecting, developing, and operating various mining properties. Petitioner's advances were not in proportion to its stock interest, were treated as loans, and interest was paid thereon monthly to March 1931. Its advances aggregated $ 8,702,000 on which repayments were made from time to time, not in proportion to stock interest and without corporate formality, leaving a balance due of $ 3,776,000, which amount was evidenced by…
1Opinion of the Court
OPINION.
Aknold, Judge:
This proceeding involves deficiencies in income and excess profits taxes for the calendar year 1937 in the respective amounts of $315,318.72, and $7,521.96. The sole issue is whether petitioner is entitled to deduct $3,117,023 as a debt ascertained to be worthless and charged off in the taxable year, representing the unpaid balance of advances made by petitioner over a period of years to the Treadwell Yukon Co., Ltd.
Facts deemed material to the issue by both parties were set forth in a stipulation of facts. Certain other facts were agreed upon in a supplemental…
2Cases cited7 opinions
- Lucas v. American Code Co.Supreme Court of the United States · 1930
- Hollins v. Brierfield Coal & Iron Co.Supreme Court of the United States · 1893
- Helvering v. Alabama Asphaltic Limestone Co.Supreme Court of the United States · 1942
- Helvering v. Southwest Consolidated Corp.Supreme Court of the United States · 1942
- Helvering v. Cement Investors, Inc.Supreme Court of the United States · 1942
2 more not listed; retrieve them via the Exa API.
3Cited by10 opinions
- Pacific Public Service Co. v. CommissionerUnited States Tax Court · 1945
- Seiberling Rubber Co. v. CommissionerUnited States Tax Court · 1947
- Benedum v. Granger, Collector of Internal Revenue (Two Cases)Court of Appeals for the Third Circuit · 1950
- de Bretteville Spreckels v. CommissionerUnited States Tax Court · 1949
- Benedum v. GrangerDistrict Court, W.D. Pennsylvania · 1949
5 more not listed; retrieve them via the Exa API.